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FORM ADV
OMB: 3235-0049
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION
Primary Business Name: HSBC SECURITIES (USA) INC. IARD/CRD Number: 19585
Rev. 10/2012

WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4.
Item 1 Identifying Information
Responses to this Item tell us who you are, where you are doing business, and how we can contact you.
A.   Your full legal name (if you are a sole proprietor, your last, first, and middle names):
HSBC SECURITIES (USA) INC.
 
B. Name under which you primarily conduct your advisory business, if different from Item 1.A.:
HSBC SECURITIES (USA) INC.

List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.
 
C. If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.), enter the new name and specify whether the name change is of
Checkbox not checked your legal name or Checkbox not checked your primary business name:
 
D. (1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-64563
(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:
 
E. If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 19585

If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.
 
F. Principal Office and Place of Business
(1) Address (do not use a P.O. Box):
Number and Street 1:
452 FIFTH AVENUE 		Number and Street 2:
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES 		ZIP+4/Postal Code:
10018

If this address is a private residence, check this box: Checkbox not checked
List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, list the largest five offices in terms of numbers of employees.
(2) Days of week that you normally conduct business at your principal office and place of business:
Radio button selected, changedMonday - Friday Radio button not selectedOther:
Normal business hours at this location:
8:30AM - 5:30PM
(3) Telephone number at this location:
212-525-2879
(4) Facsimile number at this location:
212-525-2781
 
G. Mailing address, if different from your principal office and place of business address:
Number and Street 1:
 Number and Street 2:
City:
 State:
 Country:
 ZIP+4/Postal Code:

If this address is a private residence, check this box: Checkbox not checked
 
H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:
Number and Street 1:
 Number and Street 2:
City:
 State:
 Country:
 ZIP+4/Postal Code:
Yes No
I. Do you have one or more websites? Radio button selected, changed  Radio button not selected

If "yes," list all website addresses on Section 1.I. of Schedule D. If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the other information. Some advisers may need to list more than one portal address. Do not provide individual electronic mail (e-mail) addresses in response to this Item.
 
J. Provide the name and contact information of your Chief Compliance Officer: If you are an exempt reporting adviser, you must provide the contact information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below.
Name:
 Other titles, if any:
Telephone number:
Facsimile number:
Number and Street 1:
 Number and Street 2:
City:
 State:
 Country:
 ZIP+4/Postal Code:

Electronic mail (e-mail) address, if Chief Compliance Officer has one:
 
K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, you may provide that information here.
Name:
 Titles:
Telephone number:
Facsimile number:
Number and Street 1:
 Number and Street 2:
City:
 State:
 Country:
 ZIP+4/Postal Code:

Electronic mail (e-mail) address, if contact person has one:
Yes No
L. Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than your principal office and place of business?
 Radio button selected, changed  Radio button not selected

If "yes," complete Section 1.L. of Schedule D.
Yes No
M. Are you registered with a foreign financial regulatory authority? Radio button selected, changed  Radio button not selected

Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes," complete Section 1.M. of Schedule D.
Yes No
N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934? Radio button not selected  Radio button selected, changed
If "yes," provide your CIK number (Central Index Key number that the SEC assigns to each public reporting company):
Yes No
O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year? Radio button selected, changed Radio button not selected
 
P. Provide your Legal Entity Identifier if you have one:


A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. In the first half of 2011, the legal entity identifier standard was still in development. You may not have a legal entity identifier.
 

Item 2 SEC Registration/Reporting
Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submitting an annual updating amendment to your SEC registration.
A.   To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you may affirmatively respond to each of these items.
You (the adviser):
Checkbox checked, changed   (1) are a large advisory firm that either:
(a) has regulatory assets under management of $100 million (in U.S. dollars) or more, or
(b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registered with the SEC;
Checkbox not checked (2) are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and you are either:
(a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business, or
(b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;
Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.
Checkbox not checked (3) have your principal office and place of business in Wyoming (which does not regulate advisers);
Checkbox not checked (4) have your principal office and place of business outside the United States;
Checkbox not checked (5) are an investment adviser (or sub-adviser) to an investment company registered under the Investment Company Act of 1940;
Checkbox not checked (6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;
Checkbox not checked (7) are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);
Checkbox checked, changed (8) are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, and your principal office and place of business is the same as the registered adviser;
If you check this box, complete Section 2.A.(8) of Schedule D.
Checkbox not checked (9) are a newly formed adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;
If you check this box, complete Section 2.A.(9) of Schedule D.
Checkbox not checked (10) are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);
If you check this box, complete Section 2.A.(10) of Schedule D.
Checkbox not checked (11) are an Internet adviser relying on rule 203A-2(e);
Checkbox not checked (12) have received an SEC order exempting you from the prohibition against registration with the SEC;
If you check this box, complete Section 2.A.(12) of Schedule D.
Checkbox not checked (13) are no longer eligible to remain registered with the SEC.
 
State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers
C.   Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck the box(es) next to those state(s).
 
Jurisdictions
Alabama Checkbox checked, changed AL
Alaska Checkbox checked, changed AK
Arizona Checkbox checked, changed AZ
Arkansas Checkbox checked, changed AR
California Checkbox checked, changed CA
Colorado Checkbox checked, changed CO
Connecticut Checkbox checked, changed CT
Delaware Checkbox checked, changed DE
District of Columbia Checkbox checked, changed DC
Florida Checkbox checked, changed FL
Georgia Checkbox checked, changed GA
Guam Checkbox not checked GU
Hawaii Checkbox checked, changed HI
Idaho Checkbox checked, changed ID
Illinois Checkbox checked, changed IL
Indiana Checkbox checked, changed IN
Iowa Checkbox checked, changed IA
Kansas Checkbox checked, changed KS
Kentucky Checkbox checked, changed KY
Louisiana Checkbox checked, changed LA
Maine Checkbox checked, changed ME
Maryland Checkbox checked, changed MD
Massachusetts Checkbox checked, changed MA
Michigan Checkbox checked, changed MI
Minnesota Checkbox checked, changed MN
Mississippi Checkbox checked, changed MS
Missouri Checkbox checked, changed MO
Montana Checkbox checked, changed MT
Nebraska Checkbox checked, changed NE
Nevada Checkbox checked, changed NV
New Hampshire Checkbox checked, changed NH
New Jersey Checkbox checked, changed NJ
New Mexico Checkbox checked, changed NM
New York Checkbox checked, changed NY
North Carolina Checkbox checked, changed NC
North Dakota Checkbox checked, changed ND
Ohio Checkbox checked, changed OH
Oklahoma Checkbox checked, changed OK
Oregon Checkbox checked, changed OR
Pennsylvania Checkbox checked, changed PA
Puerto Rico Checkbox checked, changed PR
Rhode Island Checkbox checked, changed RI
South Carolina Checkbox checked, changed SC
South Dakota Checkbox checked, changed SD
Tennessee Checkbox checked, changed TN
Texas Checkbox checked, changed TX
Utah Checkbox checked, changed UT
Vermont Checkbox checked, changed VT
Virgin Islands Checkbox checked, changed VI
Virginia Checkbox checked, changed VA
Washington Checkbox checked, changed WA
West Virginia Checkbox checked, changed WV
Wisconsin Checkbox checked, changed WI
 
If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31).
 

Item 3 Form of Organization
A.   How are you organized?
Radio button selected, changed Corporation
Radio button not selected Sole Proprietorship
Radio button not selected Limited Liability Partnership (LLP)
Radio button not selected Partnership
Radio button not selected Limited Liability Company (LLC)
Radio button not selected Limited Partnership (LP)
Radio button not selected Other (specify):  

If you are changing your response to this Item, see Part 1A Instruction 4.
 
B. In what month does your fiscal year end each year?

DECEMBER
 
C. Under the laws of what state or country are you organized?
State Country

Delaware
UNITED STATES

If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state or country where you reside.

If you are changing your response to this Item, see Part 1A Instruction 4.


Item 4 Successions
Yes No
A.   Are you, at the time of this filing, succeeding to the business of a registered investment adviser? Radio button not selected Radio button selected, changed
 
If "yes", complete Item 4.B. and Section 4 of Schedule D.
 
B. Date of Succession: (MM/DD/YYYY)
 
If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check “No.” See Part 1A Instruction 4.
 

Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation
Responses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1A Instruction 5.a. provides additional guidance to newly formed advisers for completing this Item 5.
Employees
 
If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs more than one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).
 
A.   Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.
1763
 
B. (1)   Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
219
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
1014
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?
216
(4) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for an investment adviser other than you?
0
(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?
216
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
0
 
In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm’s employees that solicit on your behalf.
 
Clients
 
In your responses to Items 5.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.
 
C. (1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year?
Radio button not selected 0 Radio button not selected 1-10 Radio button not selected 11-25
Radio button not selected 26-100 Radio button selected, changed More than 100
If more than 100, how many?
(round to the nearest 100)
9656
(2) Approximately what percentage of your clients are non-United States persons?
1%
 
D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not include businesses organized as sole proprietorships. The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, check "None" in response to Item 5.D.(1)(d) and do not check any of the boxes in response to Item 5.D.(2)(d).
 
(1) What types of clients do you have? Indicate the approximate percentage that each type of client comprises of your total number of clients. If a client fits into more than one category, check all that apply.
  None Up to 10% 11-25% 26-50% 51-75% 76-99% 100%
(a)  Individuals (other than high net worth individuals) Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected
(b) High net worth individuals Radio button not selected Radio button not selected Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected
(c) Banking or thrift institutions Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(d) Investment companies Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(e) Business development companies Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(f) Pooled investment vehicles (other than investment companies) Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(g) Pension and profit sharing plans (but not the plan participants) Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(h) Charitable organizations Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(i) Corporations or other businesses not listed above Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(j) State or municipal government entities Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(k) Other investment advisers Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(l) Insurance companies Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(m) Other:   Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected Radio button not selected
 
(2) Indicate the approximate amount of your regulatory assets under management (reported in Item 5.F. below) attributable to each of the following type of client. If a client fits into more than one category, check all that apply.
  None Up to 25% Up to 50% Up to 75% >75%
(a)  Individuals (other than high net worth individuals) Radio button not selected Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected
(b) High net worth individuals Radio button not selected Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected
(c) Banking or thrift institutions Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected
(d) Investment companies Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(e) Business development companies Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(f) Pooled investment vehicles (other than investment companies) Radio button not selected Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected
(g) Pension and profit sharing plans (but not the plan participants) Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected
(h) Charitable organizations Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected
(i) Corporations or other businesses not listed above Radio button not selected Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected
(j) State or municipal government entities Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(k) Other investment advisers Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(l) Insurance companies Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected
(m) Other:   Radio button selected, changed Radio button not selected Radio button not selected Radio button not selected Radio button not selected
 
Compensation Arrangements
E. You are compensated for your investment advisory services by (check all that apply):
Checkbox checked, changed   (1)    A percentage of assets under your management
Checkbox not checked (2) Hourly charges
Checkbox not checked (3) Subscription fees (for a newsletter or periodical)
Checkbox checked, changed (4) Fixed fees (other than subscription fees)
Checkbox not checked (5) Commissions
Checkbox not checked (6) Performance-based fees
Checkbox not checked (7) Other (specify):
 

Item 5 Information About Your Advisory Business - Regulatory Assets Under Management
Regulatory Assets Under Management
Yes No
F.   (1) Do you provide continuous and regular supervisory or management services to securities portfolios?
Radio button selected, changed Radio button not selected
(2) If yes, what is the amount of your regulatory assets under management and total number of accounts?
U.S. Dollar Amount Total Number of Accounts
Discretionary: (a) $ 372,034,456 (d) 1
Non-Discretionary: (b) $ 2,767,004,775 (e) 9,655
Total: (c) $ 3,139,039,231 (f) 9,656
 
Part 1A Instruction 5.b. explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.
 

Item 5 Information About Your Advisory Business - Advisory Activities
Advisory Activities
G.   What type(s) of advisory services do you provide? Check all that apply.
Checkbox not checked   (1)    Financial planning services
Checkbox not checked (2) Portfolio management for individuals and/or small businesses
Checkbox not checked (3) Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the Investment Company Act of 1940)
Checkbox checked, changed (4) Portfolio management for pooled investment vehicles (other than investment companies)
Checkbox checked, changed (5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)
Checkbox not checked (6) Pension consulting services
Checkbox checked, changed (7) Selection of other advisers (including private fund managers)
Checkbox not checked (8) Publication of periodicals or newsletters
Checkbox not checked (9) Security ratings or pricing services
Checkbox not checked (10) Market timing services
Checkbox not checked (11) Educational seminars/workshops
Checkbox checked, changed (12) Other(specify): PROVIDE ASSET ALLOC RECOMMENDATIONS & BASED UPON SUCH RECOMMENDATIONS 3RD PARTY ADV TO MANAGE ASSETS PURSUANT TO CLIENT APPROVAL
 
Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advice in Section 5.G.(3) of Schedule D.

H. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?
Radio button selected, changed  0
Radio button not selected 1 - 10
Radio button not selected 11 - 25
Radio button not selected 26 - 50
Radio button not selected 51 - 100
Radio button not selected 101 - 250
Radio button not selected 251 - 500
Radio button not selected More than 500
If more than 500, how many?
(round to the nearest 500)


In your responses to this Item 5.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.

I. If you participate in a wrap fee program, do you (check all that apply):
Checkbox checked, changed (1)   sponsor the wrap fee program?
Checkbox not checked (2) act as a portfolio manager for the wrap fee program?

If you are a portfolio manager for a wrap fee program, list the names of the programs and their sponsors in Section 5.I.(2) of Schedule D.

If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program, do not check either Item 5.I.(1) or 5.I.(2).
Yes No
J. In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments? Radio button not selected Radio button selected, changed
 

Item 6 Other Business Activities
In this Item, we request information about your firm's other business activities.
A.   You are actively engaged in business as a (check all that apply):
Checkbox checked, changed   (1)    broker-dealer (registered or unregistered)
Checkbox not checked (2) registered representative of a broker-dealer
Checkbox not checked (3) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
Checkbox checked, changed (4) futures commission merchant
Checkbox not checked (5) real estate broker, dealer, or agent
Checkbox checked, changed (6) insurance broker or agent
Checkbox not checked (7) bank (including a separately identifiable department or division of a bank)
Checkbox not checked (8) trust company
Checkbox not checked (9) registered municipal advisor
Checkbox not checked (10) registered security-based swap dealer
Checkbox not checked (11) major security-based swap participant
Checkbox not checked (12) accountant or accounting firm
Checkbox not checked (13) lawyer or law firm
Checkbox not checked (14) other financial product salesperson (specify): 
 
If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B, complete Section 6.A. of Schedule D.
Yes No
B. (1)   Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)? Radio button not selected Radio button selected, changed
(2) If yes, is this other business your primary business? Radio button not selected Radio button not selected
If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.
Yes No
(3) Do you sell products or provide services other than investment advice to your advisory clients?

Radio button selected, changed Radio button not selected
If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.

Item 7 Financial Industry Affiliations
In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you and your clients.
A.   This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and any person that is under common control with you.
   You have a related person that is a (check all that apply):
Checkbox checked, changed   (1)    broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)
Checkbox checked, changed (2) other investment adviser (including financial planners)
Checkbox not checked (3) registered municipal advisor
Checkbox not checked (4) registered security-based swap dealer
Checkbox not checked (5) major security-based swap participant
Checkbox not checked (6) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
Checkbox checked, changed (7) futures commission merchant
Checkbox checked, changed (8) banking or thrift institution
Checkbox not checked (9) trust company
Checkbox not checked (10) accountant or accounting firm
Checkbox not checked (11) lawyer or law firm
Checkbox checked, changed (12) insurance company or agency
Checkbox not checked (13) pension consultant
Checkbox not checked (14) real estate broker or dealer
Checkbox not checked (15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
Checkbox checked, changed (16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
 
For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D.

You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients.

You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.

Item 7 Private Fund Reporting
Yes No
B. Are you an adviser to any private fund?

Radio button selected, changed Radio button not selected
If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and in Instruction 6 of the Instructions to Part 1A. If another adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D.

In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name.


Item 8 Participation or Interest in Client Transactions
In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occur between you and your clients.
Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.
Proprietary Interest in Client Transactions
A.   Do you or any related person: Yes No
(1)  buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)? Radio button not selected Radio button selected, changed
(2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients? Radio button selected, changed Radio button not selected
(3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A.(1) or (2))? Radio button selected, changed Radio button not selected
 
Sales Interest in Client Transactions
B. Do you or any related person: Yes No
(1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions)? Radio button not selected Radio button selected, changed
(2) recommend purchase of securities to advisory clients for which you or any related person serves as underwriter, general or managing partner, or purchaser representative? Radio button selected, changed Radio button not selected
(3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of sales commissions as a broker or registered representative of a broker-dealer)? Radio button selected, changed Radio button not selected
 
Investment or Brokerage Discretion
C. Do you or any related person have discretionary authority to determine the: Yes No
(1) securities to be bought or sold for a client's account? Radio button selected, changed Radio button not selected
(2) amount of securities to be bought or sold for a client's account? Radio button selected, changed Radio button not selected
(3) broker or dealer to be used for a purchase or sale of securities for a client's account? Radio button selected, changed Radio button not selected
(4) commission rates to be paid to a broker or dealer for a client's securities transactions? Radio button selected, changed Radio button not selected
 
D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons? Radio button selected, changed Radio button not selected
E. Do you or any related person recommend brokers or dealers to clients? Radio button not selected Radio button selected, changed
 
F. If you answer "yes" to E above, are any of the brokers or dealers related persons? Radio button not selected Radio button not selected
G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") in connection with client securities transactions? Radio button not selected Radio button selected, changed
(2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of the Securities Exchange Act of 1934? Radio button not selected Radio button not selected
H. Do you or any related person, directly or indirectly, compensate any person for client referrals? Radio button selected, changed Radio button not selected
 
I. Do you or any related person, directly or indirectly, receive compensation from any person for client referrals? Radio button selected, changed Radio button not selected
 
In responding to Items 8.H and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H) or received from (in answering Item 8.I) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals.


Item 9 Custody
In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940) assets and about your custodial practices.
A.   (1)  Do you have custody of any advisory clients': Yes No
(a)  cash or bank accounts? Radio button selected, changed Radio button not selected
(b)  securities? Radio button selected, changed Radio button not selected
 
If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-(2)(d)(5)) from the related person.
 
(2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:
U.S. Dollar Amount Total Number of Clients
(a) $ 1,899,245,186 (b) 9,614
 
If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients’ accounts, do not include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2).
 
B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': Yes No
(a)  cash or bank accounts? Radio button selected, changed Radio button not selected
(b)  securities? Radio button selected, changed Radio button not selected
 
You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).
 
(2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons have custody:
U.S. Dollar Amount Total Number of Clients
(a) $ 1,239,794,045 (b) 42
 
C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:
(1)  A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage. Checkbox checked, changed
(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to the investors in the pools. Checkbox checked, changed
(3) An independent public accountant conducts an annual surprise examination of client funds and securities. Checkbox checked, changed
(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodians for client funds and securities. Checkbox checked, changed
 
If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the private funds you advise in Section 7.B.(1) of Schedule D).
 
D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to clients? Yes No
(1) you act as a qualified custodian Radio button not selected Radio button selected, changed
(2) your related person(s) act as qualified custodian(s) Radio button selected, changed Radio button not selected
 
If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.
 
E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide the date (MM/YYYY) the examination commenced:
09/2013
 
F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients?
2
 

Item 10 Control Persons
In this Item, we ask you to identify every person that, directly or indirectly, controls you.
If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
Yes No
A.   Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies? Radio button not selected Radio button selected, changed
 
  If yes, complete Section 10.A. of Schedule D.
 
B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934, please complete Section 10.B. of Schedule D.


Item 11 Disclosure Information
In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below.
Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.
If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.
You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.
  Yes No
Do any of the events below involve you or any of your supervised persons? Radio button selected, changed Radio button not selected
For "yes" answers to the following questions, complete a Criminal Action DRP:
A.   In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony? Radio button not selected Radio button selected, changed
(2) been charged with any felony? Radio button not selected Radio button selected, changed
 
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currently pending.
 
B. In the past ten years, have you or any advisory affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses? Radio button not selected Radio button selected, changed
(2) been charged with a misdemeanor listed in Item 11.B.(1)? Radio button not selected Radio button selected, changed
 
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are currently pending.
 
For "yes" answers to the following questions, complete a Regulatory Action DRP:
C.   Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
  (1) found you or any advisory affiliate to have made a false statement or omission? Radio button not selected Radio button selected, changed
  (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes? Radio button not selected Radio button selected, changed
  (3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? Radio button not selected Radio button selected, changed
  (4) entered an order against you or any advisory affiliate in connection with investment-related activity? Radio button not selected Radio button selected, changed
  (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity? Radio button not selected Radio button selected, changed
 
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:  
  (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical? Radio button selected, changed Radio button not selected
  (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes? Radio button selected, changed Radio button not selected
  (3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? Radio button not selected Radio button selected, changed
  (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity? Radio button selected, changed Radio button not selected
  (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity? Radio button selected, changed Radio button not selected
 
E. Has any self-regulatory organization or commodities exchange ever:
  (1) found you or any advisory affiliate to have made a false statement or omission? Radio button selected, changed Radio button not selected
  (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)? Radio button selected, changed Radio button not selected
  (3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? Radio button not selected Radio button selected, changed
  (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities? Radio button not selected Radio button selected, changed
 
F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended? Radio button not selected Radio button selected, changed
 
G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.? Radio button selected, changed Radio button not selected
 
For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H.   (1) Has any domestic or foreign court: Yes No
    (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity? Radio button not selected Radio button selected, changed
    (b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations? Radio button not selected Radio button selected, changed
    (c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority? Radio button not selected Radio button selected, changed
  (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)? Radio button not selected Radio button selected, changed
 

Item 12 Small Businesses
The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of "small business" or "small organization" under rule 0-7.
Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC to state registration.
For purposes of this Item 12 only:
  • Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is larger).
  • Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of another person is presumed to control the other person.
Yes No
A.   Did you have total assets of $5 million or more on the last day of your most recent fiscal year? Radio button not selected Radio button not selected
If "yes," you do not need to answer Items 12.B. and 12.C.
 
B. Do you:
(1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year? Radio button not selected Radio button not selected
(2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year? Radio button not selected Radio button not selected
C. Are you:
(1) controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year? Radio button not selected Radio button not selected
(2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year? Radio button not selected Radio button not selected

Part 2 Brochures
Exemption from brochure delivery requirements for SEC-registered advisers
 
SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients.  If these exemptions excuse you from delivering a brochure to all of your advisory clients, you do not have to prepare a brochure.
Yes No
Are you exempt from delivering a brochure to all of your clients under these rules? Radio button not selected Radio button selected, changed
If no, complete the ADV Part 2 filing below.
 


Brochures
Note: These documents are available as Portable Document Format (PDF) files. If you do not have the Adobe Acrobat Reader to view PDF files, please click here to download.
Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B?   Radio button selected, changedYes   Radio button not selectedNo  
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued).
6.
Ownership codes are:    NA - less than 5%    B - 10% but less than 25%    D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last Name, First Name, Middle Name)DE/FE/IStatusDate Status Acquired MM/YYYYOwnership CodeControl PersonPR CRD No. If None: S.S. No. and Date of Birth, IRS Tax No. or Employer ID No.
HSBC MARKETS (USA), INC.DEPARENT09/1998EY  13-3154043
MASSARO, TIBERIOICHIEF FINANCIAL OFFICER11/2006NAY  1847137
STEFFENSEN, MARK ALLENIGENERAL COUNSEL04/2010NAY  xxx-xx-xxxx
NOLAN, PATRICK MICHAEL MRIPRESIDENT/CEO/DIRECTOR05/2011NAY  5833589
FLANIGAN, MATTHEW JOHN IIIIHEAD OF OPERATIONS/CHIEF OPERATING OFFICER05/2011NAY  2234890
KELLY, NIAL JOSEPHIDIRECTOR08/2013NAY  6244902
VERGA, ANTHONY MATTHEWICHIEF COMPLIANCE OFFICER/DIRECTOR01/2014NAY  1845993
KATZIVE, PAULOMI SHAHIDIRECTOR06/2014NAY  5260999
KELLY, JAMES PATRICKIDIRECTOR06/2014NAY  1868918
IRELAND, ANDREW DAVIDIDIRECTOR06/2014NAY  1803463
DESCAMPS, DIDIERIDIRECTOR06/2014NAY  6136868

Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application. Schedule B asks for information about your indirect owners; you must first complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 25% or more of a class of a voting security of that corporation;

For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued).
6.
Ownership codes are:    C - 25% but less than 50%    E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last Name, First Name, Middle Name)DE/FE/IEntity in Which Interest is OwnedStatusDate Status Acquired MM/YYYYOwnership CodeControl PersonPR CRD No. If None: S.S. No. and Date of Birth, IRS Tax No. or Employer ID No.
HSBC HOLDINGS PLCFEHSBC OVERSEAS HOLDINGS (UK) LIMITEDULTIMATE PARENT COMPANY07/2005EYY 13-5146790
HSBC INVESTMENTS (NORTH AMERICA) INC.DEHSBC MARKETS (USA) INC.HOLDING COMPANY01/2004EYN 43-2027974
HSBC NORTH AMERICA HOLDINGS INC.DEHSBC INVESTMENTS (NORTH AMERICA) INC.HOLDING COMPANY01/2004EYN 23-2186091
HSBC OVERSEAS HOLDINGS (UK) LIMITEDFEHSBC NORTH AMERICA HOLDINGS INC.HOLDING COMPANY07/2005EYN 98-0460325

Schedule D

SECTION 1.B. Other Business Names

No Information Filed


SECTION 1.F. Other Offices

Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest five offices (in terms of numbers of employees).
 
Number and Street 1:
452 FIFTH AVENUE 		Number and Street 2:
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES 		ZIP+4/Postal Code:
10018
 
If this address is a private residence, check this box:  Checkbox not checked
 
Telephone Number:  
212-525-2695 		Facsimile Number:
212-525-2861
 


Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest five offices (in terms of numbers of employees).
 
Number and Street 1:
11 EAST BROADWAY 		Number and Street 2:
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES 		ZIP+4/Postal Code:
10038
 
If this address is a private residence, check this box:  Checkbox not checked
 
Telephone Number:  
212-271-1380 		Facsimile Number:
 


Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest five offices (in terms of numbers of employees).
 
Number and Street 1:
58 BOWERY 		Number and Street 2:
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES 		ZIP+4/Postal Code:
10013
 
If this address is a private residence, check this box:  Checkbox not checked
 
Telephone Number:  
212-227-1833 		Facsimile Number:
212-571-0527
 


Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest five offices (in terms of numbers of employees).
 
Number and Street 1:
55 MIRACLE MILE 		Number and Street 2:
City:
CORAL GABLES 		State:

Florida 		Country:

UNITED STATES 		ZIP+4/Postal Code:
33134
 
If this address is a private residence, check this box:  Checkbox not checked
 
Telephone Number:  
305-774-5400 		Facsimile Number:
305-774-5403
 


Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest five offices (in terms of numbers of employees).
 
Number and Street 1:
601 MONTGOMERY STREET 		Number and Street 2:
City:
SAN FRANCISCO 		State:

California 		Country:

UNITED STATES 		ZIP+4/Postal Code:
94111
 
If this address is a private residence, check this box:  Checkbox not checked
 
Telephone Number:  
415-678-3889 		Facsimile Number:
 

SECTION 1.I. Website Addresses

List your website addresses. You must complete a separate Schedule D Section 1.I. for each website address.
 
Website Address:    HTTP://WWW.US.HSBC.COM/1/2/3/PERSONAL/OTHER-SERVICES/INVESTING
 

SECTION 1.L. Location of Books and Records

Complete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separate Schedule D Section 1.L. for each location.
 
Name of entity where books and records are kept:
HSBC SECURITIES (USA) INC
 
Number and Street 1:
95 WASHINGTON STREET 		Number and Street 2:
City:
BUFFALO 		State:

New York 		Country:

UNITED STATES 		ZIP+4/Postal Code:
14203
 
If this address is a private residence, check this box:   Checkbox not checked
 
Telephone Number:  
888-662-3343 		Facsimile number:
212-382-7591
 
This is (check one):
Radio button not selected one of your branch offices or affiliates.
Radio button not selected a third-party unaffiliated recordkeeper.
Radio button selected, changed other.
 
Briefly describe the books and records kept at this location:
HSBC OPERATION DEPT. CLIENT ACCOUNT DOCUMENTATION, TRADING DOCUMENTS, CONFIRMS ETC ARE MAINTAINED
 
 
Name of entity where books and records are kept:
SEI
 
Number and Street 1:
1 FREEDOM VALLEY DRIVE 		Number and Street 2:
City:
OAKS 		State:

Pennsylvania 		Country:

UNITED STATES 		ZIP+4/Postal Code:
19456
 
If this address is a private residence, check this box:   Checkbox not checked
 
Telephone Number:  
610-676-1000 		Facsimile number:
484-676-4614
 
This is (check one):
Radio button not selected one of your branch offices or affiliates.
Radio button not selected a third-party unaffiliated recordkeeper.
Radio button selected, changed other.
 
Briefly describe the books and records kept at this location:
CONFIRMATIONS AND TRADING DOCUMENTS.
 
 
Name of entity where books and records are kept:
PERSHING LLC
 
Number and Street 1:
1 PERSHING PLAZA 		Number and Street 2:
City:
JERSEY CITY 		State:

New Jersey 		Country:

UNITED STATES 		ZIP+4/Postal Code:
07399
 
If this address is a private residence, check this box:   Checkbox not checked
 
Telephone Number:  
888-367-2563 		Facsimile number:
201-413-4640
 
This is (check one):
Radio button not selected one of your branch offices or affiliates.
Radio button selected, changed a third-party unaffiliated recordkeeper.
Radio button not selected other.
 
Briefly describe the books and records kept at this location:
PERSHING LLC ACTS AS CUSTODIAN AND CLEARING AGENT
 
 
Name of entity where books and records are kept:
IRON MOUNTAIN ARCHIVES
 
Number and Street 1:
22 KIMBERLY ROAD 		Number and Street 2:
City:
EAST BRUNSWICK 		State:

New Jersey 		Country:

UNITED STATES 		ZIP+4/Postal Code:
08816
 
If this address is a private residence, check this box:   Checkbox not checked
 
Telephone Number:  
800-899-4766 		Facsimile number:
800-934-5348
 
This is (check one):
Radio button not selected one of your branch offices or affiliates.
Radio button selected, changed a third-party unaffiliated recordkeeper.
Radio button not selected other.
 
Briefly describe the books and records kept at this location:
THIS IS AN ARCHIVAL STORAGE FACILITY THAT MAINTAINS HISTORICAL BOOKS AND RECORDS THAT ARE NO LONGER REQUIRED TO BE MAINTAINED ON-SITE.
 

SECTION 1.M. Registration with Foreign Financial Regulatory Authorities

List the name and country, in English, of each foreign financial regulatory authority with which you are registered. You must complete a separate Schedule D Section 1.M. for each foreign financial regulatory authority with whom you are registered.
 
Name of Country/Foreign Financial Regulatory Authority:

United Kingdom - Financial Conduct Authority
 
Other:
 

SECTION 2.A.(8) Related Adviser
If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:
 
Name of Registered Investment Adviser
HSBC GLOBAL ASSET MANAGEMENT (USA) INC.
 
CRD Number of Registered Investment Adviser
105686  
 
SEC Number of Registered Investment Adviser

801 - 25999  
 

SECTION 2.A.(9) Newly Formed Adviser
If you are relying on rule 203A-2(c), the newly formed adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations. You must make both of these representations:
Checkbox not checked I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within 120 days after the date my registration with the SEC becomes effective.
Checkbox not checked I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Act from registering with the SEC.
 

SECTION 2.A.(10) Multi-State Adviser
If you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.

If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:
Checkbox not checked I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the state securities authorities in those states.
Checkbox not checked I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as an investment adviser with the state securities authorities of those states.
If you are submitting your annual updating amendment, you must make this representation:
Checkbox not checked Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15 states to register as an investment adviser with the state securities authorities in those states.
 

SECTION 2.A.(12) SEC Exemptive Order
If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:
 
Application Number:
803-
 
Date of order:
 

SECTION 4 Successions

No Information Filed


SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies

No Information Filed


SECTION 5.I.(2) Wrap Fee Programs

No Information Filed


SECTION 6.A. Names of Your Other Businesses

No Information Filed


SECTION 6.B.(2) Description of Primary Business
Describe your primary business (not your investment advisory business):
 
If you engage in that business under a different name, provide that name:
 

SECTION 6.B.(3) Description of Other Products and Services
Describe other products or services you sell to your client, You may omit products and services that you listed in Section 6.B.(2) above.
PRIMARY AND SECONDARY SECURITIES, STRUCTURED CDS, STRUCTURED NOTES, FIXED AND VARIABLE ANNUITIES. SOLD TO ADVISORY CLIENTS, OFFERED THROUGH OUR AFFILIATED BROKER/DEALER. HSI IS THE ADMINISTRATIVE AGENT FOR AN ASSET-BACKED COMMERCIAL PAPER CONDUIT.
 
If you engage in that business under a different name, provide that name.
PLEASE SEE ABOVE AS REFERENCED TO OUR AFFILIATED BROKER DEALER HSBC SECURITIES USA INC.
 

SECTION 7.A. Financial Industry Affiliations

Complete a separate Schedule D Section 7.A. for each related person listed in Item 7.A.
 
1.   Legal Name of Related Person:
HSBC GLOBAL ASSET MANAGEMENT (USA) INC.
 
2. Primary Business Name of Related Person:
HSBC GLOBAL ASSET MANAGEMENT (USA) INC.
 
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)

801 - 25999    
  or
Other
 
4. Related Person's CRD Number (if any):
105686    
 
5. Related Person is: (check all that apply)
(a)   Checkbox not checked    broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) Checkbox checked, changed    other investment adviser (including financial planners)
(c) Checkbox not checked    registered municipal advisor
(d) Checkbox not checked    registered security-based swap dealer
(e) Checkbox not checked    major security-based swap participant
(f) Checkbox not checked    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) Checkbox not checked    futures commission merchant
(h) Checkbox not checked    banking or thrift institution
(i) Checkbox not checked    trust company
(j) Checkbox not checked    accountant or accounting firm
(k) Checkbox not checked    lawyer or law firm
(l) Checkbox not checked    insurance company or agency
(m) Checkbox not checked    pension consultant
(n) Checkbox not checked    real estate broker or dealer
(o) Checkbox not checked    sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) Checkbox not checked    sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person? Radio button not selected Radio button selected, changed
 
7. Are you and the related person under common control? Radio button selected, changed Radio button not selected
 
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
 Radio button not selected Radio button selected, changed
(b) If you are registering or registered with the SEC and you have answered “yes,” to question 8(a) above, have you overcome the presumption that you are not operationally independent (pursuant to rule 206(4)-(2)(d)(5)) from the related person and thus are not required to obtain a surprise examination for your clients' funds or securities that are maintained at the related person? Radio button not selected Radio button not selected
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1:
 Number and Street 2:
City:
 State:
 Country:
 ZIP+4/Postal Code:
If this address is a private residence, check this box: Checkbox not checked
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration? Radio button not selected Radio button selected, changed
(b) If the answer is yes, under what exemption?
 
10. (a) Is the related person registered with a foreign financial regulatory authority ? Radio button not selected Radio button selected, changed
(b) If the answer is yes, list the name and country, in English, of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons? Radio button selected, changed Radio button not selected
 
12. Do you and the related person share the same physical location? Radio button selected, changed Radio button not selected
 
 
1.   Legal Name of Related Person:
HSBC BANK USA, N.A.
 
2. Primary Business Name of Related Person:
HSBC BANK USA, N.A.
 
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-    
  or
Other
 
4. Related Person's CRD Number (if any):
   
 
5. Related Person is: (check all that apply)
(a)   Checkbox not checked    broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) Checkbox not checked    other investment adviser (including financial planners)
(c) Checkbox not checked    registered municipal advisor
(d) Checkbox not checked    registered security-based swap dealer
(e) Checkbox not checked    major security-based swap participant
(f) Checkbox not checked    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) Checkbox not checked    futures commission merchant
(h) Checkbox checked, changed    banking or thrift institution
(i) Checkbox not checked    trust company
(j) Checkbox not checked    accountant or accounting firm
(k) Checkbox not checked    lawyer or law firm
(l) Checkbox not checked    insurance company or agency
(m) Checkbox not checked    pension consultant
(n) Checkbox not checked    real estate broker or dealer
(o) Checkbox not checked    sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) Checkbox not checked    sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person? Radio button not selected Radio button selected, changed
 
7. Are you and the related person under common control? Radio button selected, changed Radio button not selected
 
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
 Radio button selected, changed Radio button not selected
(b) If you are registering or registered with the SEC and you have answered “yes,” to question 8(a) above, have you overcome the presumption that you are not operationally independent (pursuant to rule 206(4)-(2)(d)(5)) from the related person and thus are not required to obtain a surprise examination for your clients' funds or securities that are maintained at the related person? Radio button selected, changed Radio button not selected
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1:
452 5TH AVENUE 		Number and Street 2:
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES 		ZIP+4/Postal Code:
10018
If this address is a private residence, check this box: Checkbox not checked
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration? Radio button not selected Radio button not selected
(b) If the answer is yes, under what exemption?
 
10. (a) Is the related person registered with a foreign financial regulatory authority ? Radio button selected, changed Radio button not selected
(b) If the answer is yes, list the name and country, in English, of each foreign financial regulatory authority with which the related person is registered.
Name of Country/Foreign Financial Regulatory Authority
Other - BANCO CENTRAL DO BRASIL
Other - FINANCIAL SUPERINTENDENCE OF COLOMBIA
Other - HONG KONG MONETARY AUTHORITY
Other - OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS, CANADA
Other - SUPERINTENDENCIA DE BANCA, SEGUROS Y AFP
Other - SUPERINTENDENCIA DE BANCOS E INSTITUCIONES FINANCIERAS, CHILE
United Kingdom - Financial Conduct Authority
11. Do you and the related person share any supervised persons? Radio button not selected Radio button selected, changed
 
12. Do you and the related person share the same physical location? Radio button not selected Radio button selected, changed
 

SECTION 7.B.(1) Private Fund Reporting

 
A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    AM INVESTOR LLC
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-1647158282
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC REAL ESTATE EQUITY PARTNERS, USA L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button selected, changed real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 0

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
0

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    BRYANT PARK FUNDING, LLC.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-5932410022
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
BPF MEMBER, INC.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox not checked   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button not selected real estate fund Radio button selected, changed securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 372,034,456

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 0
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
1

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
No Information Filed
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button selected, changed Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button selected, changed No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button selected, changed Radio button not selected
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

Additional Marketer Information : 4 Record(s) Filed.


You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

  Yes No
(b) Is the marketer a related person of your firm? Radio button not selected Radio button selected, changed

(c) Name of the marketer:
CITIGROUP GLOBAL MARKETS INC.

(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):

801 - 3387    
  and CRD Number (if any):
7059    

(e) Location of the marketer's office used principally by the private fund (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(f) Does the marketer market the private fund through one or more websites? Radio button not selected Radio button selected, changed

(g) If the answer to 28(f) is "yes", list the website address(es):  
No Information Filed



You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

  Yes No
(b) Is the marketer a related person of your firm? Radio button selected, changed Radio button not selected

(c) Name of the marketer:
HSBC SECURITIES (USA) INC.

(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):

801 - 64563    
  and CRD Number (if any):
19585    

(e) Location of the marketer's office used principally by the private fund (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(f) Does the marketer market the private fund through one or more websites? Radio button not selected Radio button selected, changed

(g) If the answer to 28(f) is "yes", list the website address(es):  
No Information Filed



You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

  Yes No
(b) Is the marketer a related person of your firm? Radio button not selected Radio button selected, changed

(c) Name of the marketer:
J.P. MORGAN SECURITIES LLC

(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):

801 - 3702    
  and CRD Number (if any):
79    

(e) Location of the marketer's office used principally by the private fund (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(f) Does the marketer market the private fund through one or more websites? Radio button not selected Radio button selected, changed

(g) If the answer to 28(f) is "yes", list the website address(es):  
No Information Filed



You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

  Yes No
(b) Is the marketer a related person of your firm? Radio button selected, changed Radio button not selected

(c) Name of the marketer:
MORGAN STANLEY & CO. LLC

(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):

8 - 15869    
  and CRD Number (if any):
8209    

(e) Location of the marketer's office used principally by the private fund (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(f) Does the marketer market the private fund through one or more websites? Radio button not selected Radio button selected, changed

(g) If the answer to 28(f) is "yes", list the website address(es):  
No Information Filed

A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    DV INVESTOR LLC
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-7500779852
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC REAL ESTATE EQUITY PARTNERS USA, L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button selected, changed real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 0

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
0

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
0%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC EQUITY PARTNERS USA, L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-4762239329
   

2. Under the laws of what state or country is the private fund organized:
    State:

New York 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC EQUITY INVESTORS USA, L.P

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 97,045,643

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
100%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button not selected
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button not selected Radio button selected, changed

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC LATIN AMERICA FUND PARTNERS L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-4224681008
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HCUS LATIN AMERICA FUND INVESTORS GP LP

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button selected, changed Radio button not selected
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button selected, changed
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 29,633,901

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
100%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC LATIN AMERICA INSTITUTIONAL FUND L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-4419011058
   

2. Under the laws of what state or country is the private fund organized:
    State:
Country:

CAYMAN ISLANDS 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC LA INSTITUTIONAL INVESTORS LP

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button selected, changed Radio button not selected
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
    HSBC LATIN AMERICA PRIVATE EQUITY INVESTORS L.P.
    Private Fund Identification Number:
(include the "805-" prefix also)
    805-7678392023
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 10,579,414

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
5

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
77%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button selected, changed Radio button not selected

22. If yes, provide the private fund's Form D file number (if any):
 
Form D file number
021-114316

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button selected, changed Radio button not selected
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button selected, changed Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

Additional Auditor Information : 1 Record(s) Filed.

If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

(b) Name of the auditing firm:
  KPMG

(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):  
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(d) Is the auditing firm an independent public accountant? Radio button selected, changed Radio button not selected

(e) Is the auditing firm registered with the Public Company Accounting Oversight Board? Radio button selected, changed Radio button not selected

(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? Radio button selected, changed Radio button not selected

    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button selected, changed Radio button not selected
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA,, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC LATIN AMERICA PARTNERS L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-6086835745
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HCUS LATIN AMERICA EQUITY INVESTORS GP LP

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 36,902,403

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
6

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
1%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
63%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
93%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button selected, changed Radio button not selected

22. If yes, provide the private fund's Form D file number (if any):
 
Form D file number
021-126455

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button selected, changed Radio button not selected
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button selected, changed Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

Additional Auditor Information : 1 Record(s) Filed.

If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

(b) Name of the auditing firm:
  KPMG

(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):  
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(d) Is the auditing firm an independent public accountant? Radio button selected, changed Radio button not selected

(e) Is the auditing firm registered with the Public Company Accounting Oversight Board? Radio button selected, changed Radio button not selected

(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? Radio button selected, changed Radio button not selected

    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button selected, changed Radio button not selected
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC LATIN AMERICA PRIVATE EQUITY INVESTORS L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-7678392023
   

2. Under the laws of what state or country is the private fund organized:
    State:
Country:

CAYMAN ISLANDS 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC LATIN AMERICA PRIVATE EQUITY INVESTORS GP L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button selected, changed Radio button not selected
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
Private Fund NamePrivate Fund Identification Number
HSBC LATIN AMERICA INSTITUTIONAL FUND L.P.805-4419011058
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button selected, changed Radio button not selected
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button selected, changed Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 89,153,114

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
3

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
100%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button selected, changed Radio button not selected
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button selected, changed Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

Additional Auditor Information : 1 Record(s) Filed.

If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

(b) Name of the auditing firm:
  KPMG

(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):  
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(d) Is the auditing firm an independent public accountant? Radio button selected, changed Radio button not selected

(e) Is the auditing firm registered with the Public Company Accounting Oversight Board? Radio button selected, changed Radio button not selected

(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? Radio button selected, changed Radio button not selected

    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button selected, changed Radio button not selected
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button selected, changed Yes Radio button not selected No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC LATIN AMERICAN COINVESTMENT PARTNERS, L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-7182968992
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HCUS LA DIRECT INVESTORS GP LP

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 73,445,160

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
100%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC MEZZANINE PARTNERS USA, L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-5009694207
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC MEZZANINE INVESTORS USA, L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 16,328,270

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
100%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC PRIVATE EQUITY ACCESS FUND, L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-4080440268
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC PRIVATE EQUITY ACCESS LP

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button selected, changed Radio button not selected
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
    HSBC PRIVATE EQUITY INVESTORS CAYMAN L.P.
    Private Fund Identification Number:
(include the "805-" prefix also)
    805-5020494132
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 41,406,048

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
7

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
100%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button selected, changed Radio button not selected
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button selected, changed Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

Additional Auditor Information : 1 Record(s) Filed.

If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

(b) Name of the auditing firm:
  KPMG

(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):  
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(d) Is the auditing firm an independent public accountant? Radio button selected, changed Radio button not selected

(e) Is the auditing firm registered with the Public Company Accounting Oversight Board? Radio button selected, changed Radio button not selected

(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? Radio button selected, changed Radio button not selected

    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button selected, changed Radio button not selected
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK (USA), N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC PRIVATE EQUITY FUND PARTNERS USA L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-2652441460
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC PRIVATE EQUITY L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button selected, changed Radio button not selected
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button selected, changed
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 216,893,792

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
100%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC PRIVATE EQUITY INVESTORS CAYMAN L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-5020494132
   

2. Under the laws of what state or country is the private fund organized:
    State:
Country:

CAYMAN ISLANDS 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC PRIVATE EQUITY L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button selected, changed Radio button not selected
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
Private Fund NamePrivate Fund Identification Number
HSBC PRIVATE EQUITY ACCESS FUND, L.P.805-4080440268
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button selected, changed Radio button not selected
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button selected, changed Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 278,174,195

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
4

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
100%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button selected, changed Radio button not selected

22. If yes, provide the private fund's Form D file number (if any):
 
Form D file number
021-97528

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button selected, changed Radio button not selected
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button selected, changed Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

Additional Auditor Information : 1 Record(s) Filed.

If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

(b) Name of the auditing firm:
  KPMG

(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):  
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(d) Is the auditing firm an independent public accountant? Radio button selected, changed Radio button not selected

(e) Is the auditing firm registered with the Public Company Accounting Oversight Board? Radio button selected, changed Radio button not selected

(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? Radio button selected, changed Radio button not selected

    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button selected, changed Radio button not selected
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC PRIVATE EQUITY PARTNERS II USA L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-4823322082
   

2. Under the laws of what state or country is the private fund organized:
    State:

New York 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC PRIVATE EQUITY INVESTORS II L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 85,131,476

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
1%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
99%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
99%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button selected, changed Radio button not selected
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button selected, changed Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

Additional Auditor Information : 1 Record(s) Filed.

If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

(b) Name of the auditing firm:
  KPMG

(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):  
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(d) Is the auditing firm an independent public accountant? Radio button selected, changed Radio button not selected

(e) Is the auditing firm registered with the Public Company Accounting Oversight Board? Radio button selected, changed Radio button not selected

(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? Radio button selected, changed Radio button not selected

    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button selected, changed Radio button not selected
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button selected, changed Yes Radio button not selected No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC REAL ESTATE EQUITY PARTNERS USA, L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-5559597369
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC REAL ESTATE EQUITY INVESTORS USA, L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button selected, changed real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 13,624,342

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
100%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC REAL ESTATE FUND L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-7242116670
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC PE LP

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button selected, changed Radio button not selected
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button selected, changed
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button selected, changed real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 10,630,188

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
2

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
100%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC REAL ESTATE MEZZANINE PARTNERS USA, L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-5217920550
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC REAL ESTATE MEZZANINE INVESTORS USA, L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button selected, changed real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 0

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
0

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
0%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    HSBC USA RUTLAND INVESTORS I, L.P.
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-9507115406
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC USA RUTLAND GP LLC

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button selected, changed private equity fund Radio button not selected real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 0

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
0

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    LV INVESTOR LLC
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-2047432747
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC REAL ESTATE EQUITY PARTNERS USA, L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button selected, changed real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 0

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
0

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
0%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A.

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed


A. PRIVATE FUND

Information About the Private Fund

1. (a) Name of the private fund:
    MILANO INVESTOR LLC
  (b) Private fund identification number:
(include the "805-" prefix also)
    805-4553355699
   

2. Under the laws of what state or country is the private fund organized:
    State:

Delaware 		Country:

UNITED STATES 		   

3. Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
 
Name of General Partner, Manager, Trustee, or Director
HSBC REAL ESTATE EQUITY PARTNERS USA, L.P.

4. The private fund (check all that apply; you must check at least one):
  Checkbox checked, changed   (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
  Checkbox checked, changed   (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940

5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
 
No Information Filed
    Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
 
No Information Filed
 
    Yes No
  (c) Is this a "feeder fund" in a master-feeder arrangement? Radio button not selected Radio button selected, changed
  (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
    Name of the Private Fund:
   
    Private Fund Identification Number:
(include the "805-" prefix also)
   
   
  NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1). for the master-feeder arrangement or reporting on the funds separately.

7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder funds answer the following questions:
 

No Information Filed


 
  NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
    Yes No
8. (a) Is this private fund a "fund of funds"? Radio button not selected Radio button selected, changed
(b) If yes, does the private fund invest in funds managed by you or by a related person? Radio button not selected Radio button not selected
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles, whether or not they are also private funds, or registered investment companies.
    Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)? Radio button not selected Radio button selected, changed

10. What type of fund is the private fund?
Radio button not selected hedge fund Radio button not selected liquidity fund Radio button not selected private equity fund Radio button selected, changed real estate fund Radio button not selected securitized asset fund Radio button not selected venture capital fund Radio button not selected Other private fund
 
NOTE: For funds of funds, refer to the funds in which the private fund invests. For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
 
11. Current gross asset value of the private fund:
$ 18,053,903

Ownership

12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational documents of the fund).

13. Approximate number of the private fund's beneficial owners:
3

14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%

15. What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%

16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%

Your Advisory Services
    Yes No
17. (a) Are you a subadviser to this private fund? Radio button not selected Radio button selected, changed
(b) If the answer to question 17(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17(a) is "no," leave this question blank.
No Information Filed
    Yes No
18. (a) Do any other investment advisers advise the private fund? Radio button selected, changed Radio button not selected
(b) If the answer to question 18(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question 18(a) is "no," leave this question blank.
Name of Other Adviser to private fundSEC file numberCRD number
GRAYCLIFF PARTNERS LP 801-72820 157221
    Yes No
19. Are your clients solicited to invest in the private fund? Radio button not selected Radio button selected, changed

20. Approximately what percentage of your clients has invested in the private fund?
1%

Private Offering
    Yes No
21. Does the private fund rely on an exemption from registration of its securities under Regulation D of the Securities Act of 1933? Radio button not selected Radio button selected, changed

22. If yes, provide the private fund's Form D file number (if any):
 
No Information Filed

B. SERVICE PROVIDERS

Auditors
    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit? Radio button not selected Radio button selected, changed
(2) Are the financial statements prepared in accordance with U.S. GAAP? Radio button not selected Radio button not selected
If the answer to 23(a)(1) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one auditing firm, you must complete questions (b) through (f) separately for each auditing firm.

No Information Filed


    Yes No
(g) Are the private fund's audited financial statements distributed to the private fund's investors? Radio button not selected Radio button selected, changed
(h) Does the report prepared by the auditing firm contain an unqualified opinion?
Radio button not selected Yes Radio button not selected No Radio button selected, changed Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.

Prime Broker
    Yes No
24. (a) Does the private fund use one or more prime brokers? Radio button not selected Radio button selected, changed
If the answer to 24(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.

No Information Filed



Custodian
    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets? Radio button selected, changed Radio button not selected
If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

Additional Custodian Information : 1 Record(s) Filed.


If the answer to 25(a) is "yes," respond to questions (b) through (f) below for each custodian the private fund uses. If the private fund uses more than one custodian, you must complete questions (b) through (f) separately for each custodian.

(b) Legal name of custodian:
HSBC BANK USA, N.A

(c) Primary business name of custodian:
HBUS

(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City:
NEW YORK 		State:

New York 		Country:

UNITED STATES
  Yes No
(e) Is the custodian a related person of your firm? Radio button selected, changed Radio button not selected

(f) If the custodian is a broker-dealer, provide its SEC registration number (if any)
-    
  CRD Number (if any):
   


Administrator
    Yes No
26. (a) Does the private fund use an administrator other than your firm? Radio button not selected Radio button selected, changed
If the answer to 26(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must complete questions (b) through (f) separately for each administrator.

No Information Filed



27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation determined by such person.

Marketers
    Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes? Radio button not selected Radio button selected, changed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person. If the answer to 28(a) is "yes", respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

No Information Filed




SECTION 7.B.(2) Private Fund Reporting

No Information Filed


SECTION 9.C. Independent Public Accountant

You must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehicle that you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant.
(1) Name of the independent public accountant:
KPMG LLC
 
(2) The location of the independent public accountant's office responsible for the services provided:
Number and Street 1: Number and Street 2:
345 PARK AVENUE
City: State: Country: ZIP+4/Postal Code:
NEW YORK
New York
UNITED STATES		 10154
Yes No
(3) Is the independent public accountant registered with the Public Company Accounting Oversight Board? Radio button selected, changed Radio button not selected

(4) If yes to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? Radio button selected, changed Radio button not selected
(5) The independent public accountant is engaged to:
A. Checkbox checked, changed audit a pooled investment vehicle
B. Checkbox checked, changed perform a surprise examination of clients' assets
C. Checkbox checked, changed prepare an internal control report
 
(6) Does any report prepared by the independent public accountant that audited the pooled investment vehicle or that examined internal controls contain an unqualified opinion?
Radio button not selected Yes
Radio button selected, changed No
Radio button not selected Report Not Yet Received
If you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available.

SECTION 10.A. Control Persons

No Information Filed


SECTION 10.B. Control Person Public Reporting Companies

B.   If any person named in Schedules A, B, or C, or in Section 10 A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934 , please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company):
(1) Full legal name of the public reporting company: HSBC HOLDINGS PLC
(2) The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company): 108913
 

Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
TO CLARIFY ITEM 7.A (FINANCIAL INDUSTRY AFFILIATIONS), AS THERE ARE NO ENTITIES UNDER THE OWNERSHIP OF HSBC NORTH AMERICA INC. THAT ARE EITHER PENSION CONSULTANTS OR A REAL ESTATE BROKER OR DEALER WE HAVE NOT CHECKED ITEMS 9 AND 10. HOWEVER, THE APPLICANT IS ULTIMATELY OWNED BY HSBC HOLDINGS PLC ("HOLDINGS") WHO MAY HAVE A PENSION CONSULTANT OR REAL ESTATE BROKER OR DEALER AMONG ITS DIRECT AND INDIRECT AFFILIATES. A LIST OF SUCH ENTITIES CAN BE PROVIDED UPON REQUEST. SECTION 7 A THE APPLICANT IS ULTIMATELY OWNED BY HSBC HOLDINGS PLC ("HOLDINGS"). AMONG HOLDINGS INTERNATIONALLY HELD DIRECT AND INDIRECT AFFILIATES ARE VARIOUS INVESTMENT ADVISERS, BROKER-DEALERS, MUNICIPAL SECURITIES DEALERS, OR GOVERNMENT SECURITIES DEALERS. SOME OF THESE FIRMS HAVE NOT BEEN LISTED ON SECTION 7.A. OF SCHEDULE D SINCE THE APPLICANT HAS NO RELATIONSHIP WITH THEM OTHER THAN COMMON OWNERSHIP. A LIST OF SUCH FIRMS CAN BE PROVIDED UPON REQUEST. SECTION 7.B.-SECTION 7.B.-THE REGISTRANT HAS RELATED SEC-REGISTERED ADVISERS THAT MANAGE LIMITED PARTNERSHIPS (LPS) OR LIMITED LIABILITY COMPANIES (LLCS) THAT ARE NOT LISTED IN SECTION 7.B. OF SCHEDULE D; INFORMATION ABOUT THOSE LIMITED PARTNERSHIPS OR LIMITED LIABILITY COMPANIES IS AVAILABLE UPON REQUEST AND MAY ALSO BE AVAILABLE IN SECTION 7.B. OF THE SCHEDULE D OF THE FORM ADVS OF OUR RELATED SEC-REGISTERED ADVISERS. CLIENTS OF THE REGISTRANT ARE NOT SOLICITED TO INVEST IN THOSE LIMITED PARTNERSHIPS OR LIMITED LIABILITY COMPANIES. ITEM 8 8A(1)(2)(3) AND 8B(3) WAS ANSWERED YES IN RESPONSE TO HSI'S CONDUIT BUSINESS.
 

DRPs

CRIMINAL DISCLOSURE REPORTING PAGE (ADV)

No Information Filed


CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)

No Information Filed


REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox checked, changed 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button selected, changedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
 
2. Principal Sanction:

Other
Other Sanctions:
FINED
 
3. Date Initiated (MM/DD/YYYY):
12/04/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2012-0233-S
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Insurance
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGED THAT HSBC VIOLATED SECTION 2110(A)(2) OF THE INSURANCE LAW IN ITS RENEWAL APPLICATIONS FOR AGENT'S LICENSE UNDER SECTION 2103(A) OF THE INSURANCE LAW FOR FAILING TO DISCLOSE CERTAIN REGULATORY MATTERS AND ARBITRATION AWARDS ENTERED AGAINST HSBC.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Stipulation and Consent
 
11. Resolution Date (MM/DD/YYYY):
12/04/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 27,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC SECURITIES (USA) INC. WAIVED ITS RIGHT TO NOTICE AND A HEARING ON SAID CHARGE AND AGREED, IN LIEU OF ANY OTHER DISCIPLINARY ACTION WHICH MIGHT BE TAKEN BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES. HSBC AGREED TO FINE OF $27,500.00 AND TO TAKE ALL NECESSARY STEPS TO PREVENT THE RECURRENCE OF ANY SIMLIAR VIOLATIONS.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox checked, changed 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button selected, changedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF WASHINGTON OFFICE OF INSURANCE COMMISSIONER
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
07/27/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
11-0152
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Insurance
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF WASHINGTON OFFICE OF INSURANCE COMMISSION ("OIC")ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED RCW48.17.597(1) BY FAILING TO REPORT ADMINISTRATIVE ACTIONS TAKEN AGAINST IT BY ITS PRIMARY REGULATOR WITH THIRTY DAYS. THE OIC ALSO ALLEGED THAT HSBC VIOLATED RCW 48.17.530 BY REPRESENTING IN ITS INITIAL APPLICATION THAT IT HAD NOT BEEN NAMED IN ANY FINRA VIOLATIONS AND REPORTABLE ACTIONS. THE OIC ALLEGED THAT HSBC PROVIDED AN INCORRECT CRD NUMBER ON IT APPLICATION.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
08/01/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 7,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $7,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox checked, changed 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK FINANCE CORP
(For individuals, Last, First, Middle) 		 

CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK NORTH AMERICA HOLDINGS PLC
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB")
 
2. Principal Sanction:

Cease and Desist
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
04/13/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
11-022-B-HC 11-002-B-DEO
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FRB ALLEGES THAT HSBC ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES IN CONNECTION WITH ITS MORTGAGE LOAN SERVICING AND FORECLOSURE PRACTICES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
02/28/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 249,901,413
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
PURSUANT TO THE FRB AND OCC AMENDED CONSENT ORDERS DATED FEBRUARY 28, 2013, HSBC WILL MAKE CASH PAYMENTS TOTALLING $249,901,413. SUCH PAYMENTS WILL BE APPLIED TO A SETTLEMENT FUND AND ALSO BE USED TO PROVIDE OTHER ASSISTANCE TO HELP MORTGAGE BORROWERS.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE APRIL 2011 OCC AND FRB CONSENT ORDERS WERE AMENDED, REQUIRING HNAH, HBIO AND HSBC BANK TO PAY $96,540,359 INTO A QUALIFIED SETTLEMENT FUND, ESTABLISHED PURSUANT TO THE AMENDMENT, FROM WHICH PAYMENTS WILL BE MADE ACCORDING TO A DISTRIBUTION PLAN DEVELOPED BY THE FRB AND THE OCC. HNAH, HBIO AND HSBC BANK SHALL ALSO PROVIDE LOSS MITIGATION AND FORECLOSURE PREVENTION TOTALLING $153,361,054.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox checked, changed 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK NORTH AMERICA HOLDINGS PLC
(For individuals, Last, First, Middle) 		 

CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK FINANCE CORP
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB")
 
2. Principal Sanction:

Cease and Desist
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
04/13/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
11-022-B-HC 11-022-B-DEO
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FRB ALLEGES THAT HSBC ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES IN CONNECTION WITH ITS MORTGAGE LOAN SERVICING AND FORECLOSURE PRACTICES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
04/13/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox not checked  Monetary/Fine Amount: $
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox checked, changed  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
HSBC WAS ORDERED TO REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC AGREED TO ENTER INTO CEASE AND DESIST ORDERS WITH THE FEDERAL RESERVE BOARD AND OFFICE OF THE COMPTROLLER OF THE CURRENCY ON APRIL 13, 2011, TO REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
IN BRIEF, THE FRB CONSENT ORDER REQUIRES THE FOLLOWING: THE BOARD OF DIRECTORS OF HNAH SHALL UTILIZE HNAH'S FINANCIAL AND MANAGERIAL RESOURCES TO SERVE AS A SOURCE OF STRENGTH TO THE BANK TO ENSURE THAT THE BANK COMPLIES WITH THE CONSENT ORDER ISSUED BY THE OCC. WITHIN 60 DAYS, THE BOARDS OF DIRECTORS OF HNAH AND HBIO SHALL SUBMIT A PLAN TO STRENGTHEN THE BOARDS' OVERSIGHT OF THE MORTGAGE SERVICING COMPANIES. WITHIN 45 DAYS, HNAH AND HBIO SHALL RETAIN INDEPENDENT CONSULTANT(S) TO CONDUCT A REVIEW OF CERTAIN RESIDENTIAL MORTGAGE FORECLOSURE ACTIONS REGARDING INDIVIDUAL BORROWERS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A PLAN, ALONG WITH A TIMELINE, FOR STRENGTHENING COORDINATION OF COMMUNICATIONS BETWEEN THE MORTGAGE SERVICING COMPANIES AND BORROWERS RELATED TO LOSS MITIGATION AND FORECLOSURE ACTIVITIES. WITHIN 60 DAYS, HBIO SHALL SUBMIT POLICIES AND PROCEDURES FOR THE OUTSOURCING OF ANY RESIDENTIAL MORTGAGE LOAN SERVICING, LOSS MITIGATION, OR FORECLOSURE FUNCTIONS, BY THE MORTGAGE SERVICING COMPANIES TO ANY THIRD PARTY. WITHIN 60 DAYS, HNAH SHALL SUBMIT A PLAN TO ENHANCE ITS ENTERPRISE-WIDE COMPLIANCE PROGRAM WITH RESPECT TO ITS OVERSIGHT OF RESIDENTIAL MORTGAGE LOAN SERVICING, LOSS MITIGATION, AND FORECLOSURE ACTIVITIES AND OPERATIONS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A COMPLIANCE PROGRAM AND TIMELINE TO ENSURE THAT THE OPERATIONS OF THE MORTGAGE SERVICING COMPANIES COMPLY WITH THE LEGAL REQUIREMENTS, AS WELL AS THE MORTGAGE SERVICING COMPANIES' INTERNAL POLICIES, PROCEDURES, AND PROCESSES AND ARE CONDUCTED IN A SAFE AND SOUND MANNER. WITHIN 60 DAYS, HBIO SHALL SUBMIT A PLAN TO ENSURE APPROPRIATE CONTROLS AND OVERSIGHT OF THE MORTGAGE SERVICING COMPANIES' ACTIVITIES WITH RESPECT TO MERS AND COMPLIANCE WITH MERS' MEMBERSHIP RULES, TERMS, AND CONDITIONS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A PLAN AND TIMELINE FOR THE REVIEW AND REMEDIATION OF THE MORTGAGE SERVICING COMPANIES' MANAGEMENT INFORMATION SYSTEMS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A PLAN AND TIMELINE TO IMPROVE THE TRAINING OF ALL APPROPRIATE OFFICERS AND STAFF OF THE MORTGAGE SERVICING COMPANIES REGARDING THE LEGAL REQUIREMENTS, SUPERVISORY GUIDANCE OF THE BOARD OF GOVERNORS, AND THE MORTGAGE SERVICING COMPANIES' INTERNAL POLICIES AND PROCEDURES REGARDING RESIDENTIAL MORTGAGE LOAN SERVICING, LOSS MITIGATION, AND FORECLOSURE. WITHIN 10 DAYS, HNAH AND HBIO SHALL RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT AN ASSESSMENT OF THE MORTGAGE SERVICING COMPANIES' RISKS. THE INDEPENDENT CONSULTANT SHALL PREPARE A RISK ASSESSMENT AND PROVIDE IT TO HNAH AND HBIO WITHIN 90 DAYS, AND HNAH AND HBIO SHALL PROVIDE IT TO THE RESERVE BANK AT THE SAME TIME THAT IT IS PROVIDED TO HNAH AND HBIO. WITHIN 60 DAYS OF SUBMISSION OF THE RISK ASSESSMENT, HNAH SHALL SUBMIT A PLAN TO ENHANCE ITS ERM PROGRAM. WITHIN 60 DAYS OF SUBMISSION OF THE RISK ASSESSMENT, HNAH AND HBIO SHALL JOINTLY SUBMIT A RISK MANAGEMENT PROGRAM FOR THE MORTGAGE SERVICING COMPANIES. WITHIN 60 DAYS, HNAH SHALL SUBMIT A PLAN TO ENHANCE THE INTERNAL AUDIT PROGRAM WITH RESPECT TO RESIDENTIAL MORTGAGE LOAN SERVICING, LOSS MITIGATION, AND FORECLOSURE ACTIVITIES AND OPERATIONS. WITHIN 60 DAYS, HBIO SHALL SUBMIT AN ENHANCED WRITTEN INTERNAL AUDIT PROGRAM TO PERIODICALLY REVIEW COMPLIANCE WITH APPLICABLE THE LEGAL REQUIREMENTS AND SUPERVISORY GUIDANCE OF THE BOARD OF GOVERNORS AT THE MORTGAGE SERVICING COMPANIES. WITHIN 10 DAYS OF APPROVAL BY THE RESERVE BANK, HNAH AND HBIO, AS APPLICABLE, SHALL ADOPT THE APPROVED PLANS, PROGRAMS, POLICIES, AND PROCEDURES. WITHIN 30 DAYS AFTER THE END OF EACH CALENDAR QUARTER, HNAH'S AND HBIO'S BOARDS OF DIRECTORS SHALL JOINTLY SUBMIT PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE THIS ORDER AND THE RESULTS THEREOF. WITHIN 15 MONTHS AFTER THE DATE OF THIS ORDER, HNAH AND HBIO SHALL SUBMIT A VALIDATION REPORT PREPARED BY AN INDEPENDENT THIRD-PARTY CONSULTANT WITH RESPECT TO COMPLIANCE WITH THE ORDER DURING THE FIRST YEAR AFTER THE ORDER BECOMES EFFECTIVE.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox checked, changed 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA, N.A.
(For individuals, Last, First, Middle) 		 

CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC NORTH AMERICA HOLDINGS
(For individuals, Last, First, Middle) 		 

CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC HOLDINGS PLC
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
OFFICE OF THE COMPTROLLER OF CURRENCY ("OCC"), BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
 
2. Principal Sanction:

Cease and Desist
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
12/11/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
12-062-B-FB-; 12-062-B-FB; 12-062-CMP-HC; AA-EC-12-112; AA-EC-2012-140
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA, N.A., HSBC NORTH AMERICA HOLDINGS AND HSBC HOLDINGS PLC
 
6. Principal Product Type:

No Product
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
US REGULATORY AUTHORITIES' INVESTIGATIONS REGARDING INADEQUATE COMPLIANCE WITH ANTI-MONEY LAUNDERING AND SANCTIONS LAWS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
N/A
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
12/11/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 1,921,000,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox checked, changed  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
ON DECEMBER 11, 2012, HSBC HOLDINGS PLC ANNOUNCED THAT HSBC BANK USA, N.A., HAD IN RELATION TO INVESTIGATIONS REGARDING INADEQUATE COMPLIANCE WITH ANTI-MONEY LAUNDERING AND SANCTIONS LAWS ENTERED INTO (I) AN AGREEMENT AND CONSENT ORDERS WITH THE OCC,(II) A CONSENT AND ASSESSMENT WITH THE UNITED STATES DEPARTMENT OF THE TREASURY'S FINANCIAL CRIMES ENFORCEMENT NETWORK, (III) A DEFERRED PROSECUTION AGREEMENT AMONG HSBC BANK USA, N.A., HSBC HOLDINGS PLC, THE UNITED STATES DEPARTMENT OF JUSTICE, THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK, AND THE UNITED STATES ATTORNEY'S OFFICE FOR THE NORTHERN DISTRICT OF WEST VIRGINIA; AND, HSBC HOLDINGS PLC ENTERED IN TO A DEFERRED PROSECUTION AGREEMENT WITH THE DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK, (II) CONSENTED TO A CEASE AND DESIST ORDER AND ALONG WITH HSBC NORTH AMERICA HOLDINGS CONSENTED TO A MONETARY PENALTY ORDER WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. UNDER THESE AGREEMENTS, HSBC HOLDINGS PLC AND ITS SUBSIDIARIES HAVE MADE PAYMENTS TOTALING $1.921 BILLION, CONTINUE TO COOPERATE FULLY WITH REGULATORY AND LAW ENFORCEMENT AUTHORITIES, AND TAKE FURTHER ACTION TO STRENGTHEN ITS COMPLIANCE POLICIES AND PROCEDURES. HSBC BANK USA, N.A. MAY NOT DIRECTLY OR INDIRECTLY ACQUIRE CONTROL OF, OR HOLD AN INTEREST IN, ANY NEW FINANCIAL SUBSIDIARY, NOR COMMENCE A NEW ACTIVITY IN ITS EXISTING FINANCIAL SUBSIDIARY, UNLESS IT RECEIVES PRIOR APPROVAL FROM THE OCC.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
ON DECEMBER 11, 2012, HSBC HOLDINGS PLC ANNOUNCED THAT HSBC BANK USA, N.A., HAD IN RELATION TO INVESTIGATIONS REGARDING INADEQUATE COMPLIANCE WITH ANTI-MONEY LAUNDERING AND SANCTIONS LAWS ENTERED INTO (I) AN AGREEMENT AND CONSENT ORDERS WITH THE OCC,(II) A CONSENT AND ASSESSMENT WITH THE UNITED STATES DEPARTMENT OF THE TREASURY'S FINANCIAL CRIMES ENFORCEMENT NETWORK, (III) A DEFERRED PROSECUTION AGREEMENT AMONG HSBC BANK USA, N.A., HSBC HOLDINGS PLC, THE UNITED STATES DEPARTMENT OF JUSTICE, THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK, AND THE UNITED STATES ATTORNEY'S OFFICE FOR THE NORTHERN DISTRICT OF WEST VIRGINIA; AND, HSBC HOLDINGS PLC ENTERED IN TO A DEFERRED PROSECUTION AGREEMENT WITH THE DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK, (II) CONSENTED TO A CEASE AND DESIST ORDER AND ALONG WITH HSBC NORTH AMERICA HOLDINGS CONSENTED TO A MONETARY PENALTY ORDER WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. UNDER THESE AGREEMENTS, HSBC HOLDINGS PLC AND ITS SUBSIDIARIES HAVE MADE PAYMENTS TOTALING $1.921 BILLION, CONTINUE TO COOPERATE FULLY WITH REGULATORY AND LAW ENFORCEMENT AUTHORITIES, AND TAKE FURTHER ACTION TO STRENGTHEN ITS COMPLIANCE POLICIES AND PROCEDURES. HSBC BANK USA, N.A. MAY NOT DIRECTLY OR INDIRECTLY ACQUIRE CONTROL OF, OR HOLD AN INTEREST IN, ANY NEW FINANCIAL SUBSIDIARY, NOR COMMENCE A NEW ACTIVITY IN ITS EXISTING FINANCIAL SUBSIDIARY, UNLESS IT RECEIVES PRIOR APPROVAL FROM THE OCC.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox checked, changed 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA N.A.
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC")
 
2. Principal Sanction:

Cease and Desist
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
04/13/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
AA-EC-11-14
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OCC ALLEGES THAT HSBC ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES IN CONNECTION WITH ITS MORTGAGE LOAN SERVICING AND FORCLOSURE PRACTICES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
02/28/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 249,901,413
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
PURSUANT TO THE FRB AND OCC AMENDED CONSENT ORDERS DATED FEBRUARY 28, 2013, HSBC WILL MAKE CASH PAYMENTS TOTALLING $249,901,413. SUCH PAYMENTS WILL BE APPLIED TO A SETTLEMENT FUND AND ALSO BE USED TO PROVIDE OTHER ASSISTANCE TO HELP MORTGAGE BORROWERS.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE APRIL 2011 OCC AND FRB CONSENT ORDERS WERE AMENDED, REQUIRING HNAH, HBIO AND HSBC BANK TO PAY $96,540,359 INTO A QUALIFIED SETTLEMENT FUND, ESTABLISHED PURSUANT TO THE AMENDMENT, FROM WHICH PAYMENTS WILL BE MADE ACCORDING TO A DISTRIBUTION PLAN DEVELOPED BY THE FRB AND THE OCC. HNAH, HBIO AND HSBC BANK SHALL ALSO PROVIDE LOSS MITIGATION AND FORECLOSURE PREVENTION TOTALLING $153,361,054.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox checked, changed 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA, N.A.
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC")
 
2. Principal Sanction:

Cease and Desist
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
04/13/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
AA-EC-11-14
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OCC ALLEGES THAT HSBC ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES IN CONNECTION WITH ITS MORTGAGE LOAN SERVICING AND FORECLOSURE PRACTICES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
04/13/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox not checked  Monetary/Fine Amount: $
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox checked, changed  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
HSBC WAS ORDERED TO REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC AGREED TO ENTER INTO CEASE AND DESIST ORDERS WITH THE FEDERAL RESERVE BOARD AND OFFICE OF THE COMPTROLLER OF THE CURRENCY ON APRIL 13, 2011, TO REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
IN BRIEF, THE OCC CONSENT ORDER REQUIRES THE FOLLOWING: THE HSBC BOARD OF DIRECTORS MAINTAIN A COMPLIANCE COMMITTEE WHICH SHALL SUBMIT A PROGRESS REPORT TO THE BOARD DETAILING ACTIONS TAKEN TO COMPLY WITH THIS ORDER, AND THE RESULTS AND STATUS OF THOSE ACTIONS. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN DESCRIBING THE ACTIONS NECESSARY AND APPROPRIATE TO ACHIEVE COMPLIANCE WITH THIS ORDER. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A COMPLIANCE PROGRAM TO ENSURE THAT THE MORTGAGE SERVICING AND FORECLOSURE OPERATIONS COMPLY WITH ALL APPLICABLE LEGAL REQUIREMENTS, OCC SUPERVISORY GUIDANCE, AND THE REQUIREMENTS OF THIS ORDER AND ARE CONDUCTED IN A SAFE AND SOUND MANNER. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE POLICIES AND PROCEDURES FOR OUTSOURCING FORECLOSURE OR RELATED FUNCTIONS AND PROPERTY MANAGEMENT FUNCTIONS FOR RESIDENTIAL REAL ESTATE ACQUIRED THROUGH OR IN LIEU OF FORECLOSURE, TO ANY AGENT, INDEPENDENT CONTRACTOR, CONSULTING FIRM, LAW FIRM, PROPERTY MANAGEMENT FIRM, OR OTHER THIRD-PARTY. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN TO ENSURE APPROPRIATE CONTROLS AND OVERSIGHT OF THE BANK'S ACTIVITIES WITH RESPECT TO THE MORTGAGE ELECTRONIC REGISTRATION SYSTEM AND COMPLIANCE WITH MERSCORP'S MEMBERSHIP RULES, TERMS, AND CONDITIONS. WITHIN FORTY-FIVE DAYS, THE BANK SHALL RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT AN INDEPENDENT REVIEW OF CERTAIN RESIDENTIAL FORECLOSURE ACTIONS REGARDING INDIVIDUAL BORROWERS WITH RESPECT TO THE BANK'S MORTGAGE SERVICING PORTFOLIO. THE INDEPENDENT CONSULTANT SHALL PREPARE A REPORT DETAILING THE FINDINGS OF THE FORECLOSURE REVIEW, WHICH SHALL BE COMPLETED WITHIN THIRTY DAYS OF COMPLETION OF THE FORECLOSURE REVIEW. WITHIN FORTY-FIVE DAYS OF SUBMISSION OF THE FORECLOSURE REPORT TO THE DEPUTY COMPTROLLER, EXAMINER-IN-CHARGE, AND THE BOARD, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN, ACCEPTABLE TO THE OCC, TO REMEDIATE ALL FINANCIAL INJURY TO BORROWERS CAUSED BY ANY ERRORS, MISREPRESENTATIONS, OR OTHER DEFICIENCIES IDENTIFIED IN THE FORECLOSURE REPORT. WITHIN SIXTY DAYS AFTER THE OCC PROVIDES SUPERVISORY NON-OBJECTION TO THE PLAN, THE BANK SHALL MAKE ALL PAYMENTS AND PROVIDE ALL CREDITS REQUIRED BY SUCH PLAN, AND PROVIDE THE OCC WITH A REPORT DETAILING SUCH PAYMENTS AND CREDITS. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE AN ACCEPTABLE PLAN FOR OPERATION OF ITS MANAGEMENT INFORMATION SYSTEMS ("MIS") FOR FORECLOSURE AND LOSS MITIGATION OR LOAN MODIFICATION ACTIVITIES TO ENSURE THE TIMELY DELIVERY OF COMPLETE AND ACCURATE INFORMATION TO PERMIT EFFECTIVE DECISION-MAKING. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN, ALONG WITH A TIMELINE FOR ENSURING EFFECTIVE COORDINATION OF COMMUNICATIONS WITH BORROWERS, RELATED TO LOSS MITIGATION OR LOAN MODIFICATION AND FORECLOSURE ACTIVITIES. WITHIN NINETY DAYS, THE BANK SHALL CONDUCT A COMPREHENSIVE ASSESSMENT OF THE BANK'S RISKS IN MORTGAGE SERVICING OPERATIONS. THE BANK SHALL SUBMIT THE PLANS, PROGRAMS, POLICIES, AND PROCEDURES REQUIRED BY THIS ORDER FOR REVIEW AND DETERMINATION OF NO SUPERVISORY OBJECTION TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE WITHIN THE APPLICABLE TIME PERIODS. THE BANK SHALL ADOPT THE PLANS, PROGRAMS, POLICIES, AND PROCEDURES REQUIRED BY THIS ORDER UPON SUBMISSION TO THE OCC, AND SHALL IMMEDIATELY MAKE ANY REVISIONS REQUESTED BY THE DEPUTY COMPTROLLER OR THE EXAMINER-IN-CHARGE. WITHIN THIRTY DAYS AFTER THE END OF EACH CALENDAR QUARTER FOLLOWING THE DATE OF THIS ORDER, THE BANK SHALL SUBMIT TO THE OCC A WRITTEN PROGRESS REPORT DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE PROVISIONS OF THIS ORDER AND THE RESULTS THEREOF.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox checked, changed 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC NORTH AMERICA HOLDINGS, INC.
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FEDERAL RESERVE BANK OF CHICAGO
 
2. Principal Sanction:

Cease and Desist
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
10/04/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
10-202-B-HC
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC NORTH AMERICA HOLDINGS, INC.
 
6. Principal Product Type:

No Product
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FEDERAL RESERVE BANK OF CHICAGO (THE "RESERVE BANK") REVIEWED AND ASSESSED THE EFFECTIVENESS OF HSBC NORTH AMERICA HOLDINGS, INC'S. ("HNAH") CORPORATE GOVERNANCE AND COMPLIANCE RISK MANAGEMENT PRACTICES, POLICIES, AND INTERNAL CONTROLS, AND IDENTIFIED DEFICIENCIES. HNAH AND THE BOARD OF GOVERNORS MUTUALLY AGREED TO ENTER INTO A CONSENT CEASE AND DESIST ORDER (THE "ORDER"). PURSUANT TO SECTIONS 8(B)(1) AND (3) OF THE FDI ACT (12U.S.C. §§1818(B)(1) AND 1818(B)(3)), HNAH AND ITS INSTITUTION-AFFILIATED PARTIES SHALL CEASE AND DESIST AND TAKE AFFIRMATIVE ACTION WITH RESPECT TO THE DEFICIENCIES DOCUMENTED IN THE ORDER.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
10/04/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox not checked  Monetary/Fine Amount: $
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox checked, changed  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
CONSENT CEASE AND DESIST ORDER REQUIRING COMPLIANCE WITH THE PROVISIONS LISTED IN THE SUMMARY SECTION OF THIS DRP.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE RESERVE BANK REVIEWED AND ASSESSED THE EFFECTIVENESS OF HNAH'S CORPORATE GOVERNANCE AND COMPLIANCE RISK MANAGEMENT PRACTICES, POLICIES, AND INTERNAL CONTROLS, AND IDENTIFIED THE FOLLOWING AS CORRECTIVE ACTIONS TO BE TAKEN: SOURCE OF STRENGTH - THE BOARD OF DIRECTORS OF HNAH SHALL TAKE STEPS TO FULLY UTILIZE HNAH'S FINANCIAL AND MANAGERIAL RESOURCES, PURSUANT TO SECTION 225.4(A) OF REGULATION Y OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (12 C.F.R. §225.4(A)), TO SERVE AS A SOURCE OF STRENGTH TO THE BANKS. BOARD OVERSIGHT - WITHIN 30 DAYS OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL SUBMIT TO THE RESERVE BANK AN ACCEPTABLE WRITTEN PLAN TO STRENGTHEN BOARD OVERSIGHT OF HNAH'S COMPLIANCE RISK MANAGEMENT PROGRAM. REGIONAL COMPLIANCE OFFICER - WITHIN 60 DAYS OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL TAKE SUCH ACTIONS AS ARE NECESSARY TO EMPLOY A PERMANENT FULL-TIME REGIONAL COMPLIANCE OFFICER WITH DEMONSTRATED KNOWLEDGE AND EXPERIENCE IN MANAGING A COMPLIANCE RISK MANAGEMENT PROGRAM AT AN ENTITY WITH A COMPLEX COMPLIANCE PROFILE. COMPLIANCE RISK ASSESSMENT - WITHIN 30 DAYS OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL SUBMIT TO THE RESERVE BANK A WRITTEN FIRMWIDE COMPLIANCE RISK ASSESSMENT. COMPLIANCE RISK MANAGEMENT PROGRAM - WITHIN 60 DAYS OF THE SUBMISSION OF THE FIRMWIDE COMPLIANCE RISK ASSESSMENT, HNAH'S BOARD OF DIRECTORS SHALL SUBMIT AN ACCEPTABLE WRITTEN PLAN TO THE RESERVE BANK TO IMPROVE GOVERNANCE, STRUCTURE, AND OPERATIONS OF THE COMPLIANCE RISK MANAGEMENT PROGRAM. BSA/AML COMPLIANCE - WITHIN 10 DAYS OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL RETAIN AN INDEPENDENT CONSULTANT ACCEPTABLE TO THE RESERVE BANK TO COMPLETE A REVIEW OF THE EFFECTIVENESS OF THE FIRMWIDE BSA/AML COMPLIANCE PROGRAM ADOPTED BY HNAH AND PREPARE A WRITTEN REPORT OF FINDINGS AND RECOMMENDATIONS. SUSPICIOUS ACTIVITY MONITORING AND REPORTING - WITHIN 60 DAYS OF COMPLETION OF THE BSA/AML COMPLIANCE REVIEW, HNAH SHALL SUBMIT TO THE RESERVE BANK AN ACCEPTABLE WRITTEN PROGRAM DESIGNED TO REASONABLY ENSURE PROPER REPORTING BY HNAH AND ITS SUBSIDIARIES OF ALL KNOWN OR SUSPECTED VIOLATIONS OF LAW OR SUSPICIOUS TRANSACTIONS TO LAW ENFORCEMENT AND SUPERVISORY AUTHORITIES. PROGRESS REPORTS - WITHIN 30 DAYS AFTER THE END OF EACH CALENDAR QUARTER FOLLOWING THE DATE OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL SUBMIT TO THE RESERVE BANK WRITTEN PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE ORDER. APPROVAL AND IMPLEMENTATION OF PLANS, PROGRAM, AND ENGAGEMENT LETTER - HNAH SHALL SUBMIT WRITTEN PLANS AND A PROGRAM THAT ARE ACCEPTABLE TO THE RESERVE BANK WITHIN THE APPLICABLE TIME PERIODS SET FORTH IN THE ORDER.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox checked, changed 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA, N.A.
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC")
 
2. Principal Sanction:

Cease and Desist
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
10/06/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
AA-EC-10-98
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA, N.A.
 
6. Principal Product Type:

No Product
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA ("COMPTROLLER"), THROUGH HIS NATIONAL BANK EXAMINERS AND OTHER STAFF OF THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC"), CONDUCTED AN EXAMINATION AND INVESTIGATION OF THE PAYMENTS AND CASH MANAGEMENT ("PCM"), GLOBAL BANKNOTES, AND FOREIGN CORRESPONDENT OPERATIONS OF HSBC BANK USA, N.A., MCLEAN, VIRGINIA ("BANK"). THE OCC HAS IDENTIFIED DEFICIENCIES IN THE BANK'S INTERNAL CONTROLS FOR THESE AREAS AS WELL AS ITS OVERALL PROGRAM FOR BANK SECRECY ACT/ANTI-MONEY LAUNDERING ("BSA/AML") COMPLIANCE.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
10/06/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox not checked  Monetary/Fine Amount: $
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox checked, changed  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
CONSENT CEASE AND DESIST ORDER ISSUED BY THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA THROUGH HIS NATIONAL BANK EXAMINERS AND OTHER STAFF OF THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC"). THE BANK COMMITTED TO TAKING ALL NECESSARY STEPS TO REMEDY THE DEFICIENCIES IDENTIFIED BY THE OCC, AND ENHANCE THE BANK'S BSA/AML COMPLIANCE PROGRAM.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE OCC CONDUCTED AN EXAMINATION AND INVESTIGATION OF THE PCM, GLOBAL BANKNOTES, AND FOREIGN CORRESPONDENT OPERATION OF THE BANK AND IDENTIFIED THE FOLLOWING AS CORRECTIVE ACTIONS TO BE TAKEN: COMPLIANCE COMMITTEE - THE BOARD SHALL MAINTAIN A COMPLIANCE COMMITTEE OF AT LEAST THREE (3) DIRECTORS, OF WHICH AT LEAST TWO (2) MAY NOT BE EMPLOYEES OR OFFICERS OF THE BANK OR ANY OF ITS SUBSIDIARIES OR AFFILIATES. THE COMMITTEE SHALL BE RESPONSIBLE FOR MONITORING AND COORDINATING THE BANK'S ADHERENCE TO THE PROVISIONS OF THE ORDER. COMPREHENSIVE BSA/AML ACTION PLAN - WITHIN 60 DAYS OF THE ORDER, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN CONTAINING A COMPLETE DESCRIPTION OF THE ACTIONS THAT ARE NECESSARY AND APPROPRIATE TO ACHIEVE FULL COMPLIANCE WITH THE ORDER. MANAGEMENT - WITHIN FIFTEEN (15) DAYS OF THE ORDER, THE BOARD SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND EXAMINER-IN-CHARGE A PLAN TO RECRUIT, HIRE, APPOINT, AND RETAIN A QUALIFIED, PERMANENT REGIONAL COMPLIANCE OFFICER AND A QUALIFIED, PERMANENT BSA OFFICER. REVIEW OF BSA COMPLIANCE PROGRAM - WITHIN TEN (10) DAYS OF THE ORDER, THE BANK SHALL RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT AN INDEPENDENT REVIEW OF THE BANK'S BSA/AML COMPLIANCE PROGRAM. BSA COMPLIANCE PROGRAM - WITHIN 90 DAYS OF THE ORDER, THE BOARD AND EXECUTIVE MANAGEMENT SHALL ENSURE THAT A BSA/AML PROGRAM IS IN PLACE WHICH MEETS SPECIFIC CRITERIA OUTLINED IN THE ORDER. MANAGEMENT INFORMATION - WITHIN 90 DAYS OF THIS ORDER, THE BOARD SHALL ENSURE THAT BANK MANAGEMENT CONDUCTS A MANAGEMENT INFORMATION SYSTEM ASSESSMENT, AND DEVELOPS A PLAN THAT WILL ENABLE MANAGEMENT TO MORE EFFECTIVELY IDENTIFY, MONITOR, AND MANAGE THE BANK'S BSA RISKS ON A TIMELY BASIS. CDD AND EDD INFORMATION - THE BANK SHALL DEVELOP AND IMPLEMENT APPROPRIATE POLICIES AND PROCEDURES FOR GATHERING CUSTOMER DUE DILIGENCE AND ENHANCED DUE DILIGENCE INFORMATION. MONITORING - WITHIN 60 DAYS OF THE ORDER, THE BANK SHALL SUBMIT REVISED POLICIES AND PROCEDURES FOR WIRE MONITORING USING ITS CURRENT WIRE MONITORING SYSTEM TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE. SUSPICIOUS ACTIVITY REPORTING - THE BANK SHALL DEVELOP AND MAINTAIN A WRITTEN PROGRAM OF POLICIES AND PROCEDURES TO ENSURE, PURSUANT TO 12 C.F.R. § 21.11, THE TIMELY AND APPROPRIATE REVIEW AND DISPOSITIONING OF SUSPICIOUS ACTIVITY ALERTS, AND THE TIMELY FILING OF SARS. ACCOUNT/TRANSACTION ACTIVITY REVIEW ("LOOK-BACK") - THE BANK SHALL RETAIN ON OR MORE INDEPENDENT CONSULTANTS TO CONDUCT AN INDEPENDENT REVIEW OF ACCOUNT AND TRANSACTION ACTIVITY ("LOOK-BACK") COVERING AREAS TO BE SPECIFIED IN WRITING BY THE EXAMINER-IN-CHARGE. RESTRICTIONS ON GROWTH, NEW PRODUCTS AND HIGH-RISK LINES OF BUSINESS - THE BANK INFORMED THE OCC THAT IT IS EXITING THE GLOBAL BANKNOTES LINE OF BUSINESS FOR NON-DOMESTIC CUSTOMERS. IF, IN THE FUTURE, THE BANK INTENDS TO RE-ENTER THE INTERNATIONAL BULK CASH LINE OF BUSINESS, THE BANK SHALL NOTIFY THE EXAMINER-IN-CHARGE OF ITS PLAN IN WRITING AND OBTAIN WRITTEN SUPERVISORY NON-OBJECTION PRIOR TO COMMENCING RE-ENTRY. REMOTE DEPOSIT CAPTURE - THE BANK SHALL ESTABLISH CONTROLS, COMMENSURATE WITH ITS BSA/AML RISK, OVER THE USAGE OF RDC BY FOREIGN CORRESPONDENT CUSTOMERS, AND THE BANK'S MONITORING OF RDC TRANSACTIONS. BSA TRAINING - WITHIN 90 DAYS OF THIS ORDER, THE BANK SHALL DEVELOP, IMPLEMENT, AND THEREAFTER ADHERE TO A COMPREHENSIVE TRAINING PROGRAM FOR ALL APPROPRIATE OPERATIONAL AND SUPERVISORY PERSONNEL TO ENSURE THEIR AWARENESS OF THEIR RESPONSIBILITY FOR COMPLIANCE WITH THE REQUIREMENTS OF THE OFFICE OF FOREIGN ASSETS CONTROL ("OFAC") AND THE BSA, INCLUDING REPORTING REQUIREMENTS ASSOCIATED WITH SARS, PURSUANT TO 12 C.F.R. PART 21, SUBPART B, REGARDLESS OF THE SIZE OF THE RELATIONSHIP OR TYPE OF CUSTOMER INVOLVED. BSA INDEPENDENT TESTING AND AUDIT - THE BANK SHALL DEVELOP AND MAINTAIN AN EFFECTIVE PROGRAM TO AUDIT THE BANK'S BSA/AML COMPLIANCE PROGRAM.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox checked, changed 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA, NATIONAL ASSOCIATION
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
US DEPARTMENT OF THE TREASURY, OFFICE OF FOREIGN ASSET CONTROL ("OFAC")
 
2. Principal Sanction:

Other
Other Sanctions:
HSBC BANK USA, N.A.(HBUS) SETTLED POTENTIAL CIVIL LIABILITY FOR THREE APPARENT VIOLATIONS OF THE GLOBAL TERRORISM SANCTIONS REGULATIONS, 31 C.F.R. PART 594
 
3. Date Initiated (MM/DD/YYYY):
02/01/2011 Radio button not selected  Exact   Radio button selected, changed  Explanation
If not exact, provide explanation:
THIS IS THE DATE OF THE ADMINISTRATIVE SUBPOENA TO HBUS INITIATED BY OFAC IN RELATION TO THE REGULATORY ACTION BEING REPORTED.
 
4. Docket/Case Number:
SDGT-548003
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK (USA), N.A.
 
6. Principal Product Type:

Other
Other Product Types:
HBUS IS A FINANCIAL INSTITUTION INCORPORATED UNDER THE LAWS OF THE UNITED STATES AND IS REGULATED BY THE DEPARTMENT OF THE TREASURY'S OFFICE OF THE COMPTROLLER OF THE CURRENCY.
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
HBUS ALLEGEDLY PROCESSED 3 FUNDS TRANSFERS FOR THE ECONOMIC BENEFIT OF PARTIES DESIGNATED AS SPECIALLY DESIGNATED GLOBAL TERRORISTS (SDGTS). THE AGGRAVATING FACTORS IENTIFIED BY OFAC WERE: (1) HBUS DID NOT SCREEN TRANSACTION INSTRUCTIONS APPROPRIATELY AT THE TIME OF THE FIRST APPARENT VIOLATION. (2) HBUS COMPLIANCE MANAGERS FOR OFAC WERE AWARE OF THE FIRST VIOLATION AND SHOULD HAVE BEEN AWARE OF THE SECOND AND THIRD APPARENT VIOLATIONS. (3) HBUS INITIALLY PROVIDED AN INCOMPLETE RESPONSE TO AN ADMINISTRATIVE SUBPOENA.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
HBUS SETTLED WITH OFAC ALL POTENTIAL CIVIL LIABILITY FOR THE APPARENT VIOLATIONS OF THE GLOBAL TERRORISM SANCTIONS REGULATIONS EFFECTIVE ON DECEMBER 12, 2013. THE DATE WHEN OFAC SIGNED THE SETTLEMENT AGREEMENT.
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
12/12/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 32,400
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
DISPOSITION OF THE MATTER RESULTED IN A FINE OF $32400. THE WHOLE FINE WAS LEVIED ON HBUS. PAYMENT OF THE FINE WAS TMADE TIMELY, WITHIN 30 DAYS FROM DECEMBER 12, 2013.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox checked, changed 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CENSURE
 
3. Date Initiated (MM/DD/YYYY):
04/22/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2008013863801
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
AUCTION RATE SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DURING THE PERIOD FROM MAY 31, 2006 THROUGH FEBRUARY 28, 2008 ("RELEVANT PERIOD"), EXCEPT AS OTHERWISE NOTED, HSBC SECURITIES VIOLATED CERTAIN NASD, FINRA, AND MSRB RULES BY (1) MAKING NEGLIGENT MISREPRESENTATIONS AND OMISSIONS OF MATERIAL FACTS TO CUSTOMERS CONCERNING THE SAFETY AND LIQUIDITY OF AUCTION RATE SECURITIES ("ARS"); (2) USING ADVERTISING AND MARKETING MATERIALS THAT WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS ABOUT PURCHASING ARS; (3) SELLING RESTRICTED, AND THEREFORE UNSUITABLE, ARS TO CERTAIN NON-QUALIFIED CUSTOMERS; (4) FAILING TO RETAIN CERTAIN EMAILS FROM MAY 2004 TO APRIL 2009, AND FAILING TO RETAIN CERTAIN INTERNAL INSTANT MESSAGES FROM FEBRUARY 2007 TO SEPTEMBER 2008; AND (5) FAILING TO MAINTAIN ADEQUATE SUPERVISORY PROCEDURES CONCERNING ITS SALES AND MARKETING ACTIVITIES REGARDING ARS AND ITS RETENTION OF CERTAIN EMAILS AND INSTANT MESSAGES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
04/22/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 1,500,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
REPURCHASE OFFER
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING FINRA'S FINDINGS AND WITHOUT ADJUDICATION OF ANY ISSUE OF LAW OR FACT, HSBC SECURITIES CONSENTED, SOLELY FOR THE PURPOSE OF THIS PROCEEDING, TO THE ENTRY OF FINRA'S FINDINGS AND THE FOLLOWING SANCTIONS: A CENSURE AND FINE IN THE AMOUNT OF $1.5 MILLION; OFFERING TO REPURCHASE ELIGIBLE ARS FROM INVESTORS IN THE RELEVANT CLASS; MAKING BEST EFFORTS TO PROVIDE LIQUIDITY TO INVESTORS WHO PURCHASED ARS DURING THE RELEVANT PERIOD BUT WHO WERE NOT IN THE RELEVANT CLASS; FOR ANY INVESTOR IN THE RELEVANT CLASS WHO SOLD ELIGIBLE ARS BELOW PAR BETWEEN CERTAIN DATES, PAYING THE DIFFERENCE BETWEEN PAR AND THE SALE PRICE; ARBITRATING CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY ELIGIBLE INVESTORS IN THE RELEVANT CLASS UNDER FINRA'S SPECIAL ARBITRATION PROCEDURES; AND PROVIDING FINRA WITH CERTAIN REPORTS. THE SPECIFIC TERMS OF THE REPURCHASE OFFER ARE DEFINED IN THE AWC.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
IN DETERMINING THE SANCTIONS IN THIS MATTER, FINRA TOOK INTO ACCOUNT HSBC SECURITIES' VOLUNTARY REMEDIATION TO CUSTOMERS PRIOR TO THE ENTRY OF THE AWC, WHICH INCLUDED HSBC SECURITIES' VOLUNTARY REPURCHASE OF ARS FROM ITS CUSTOMERS IN 2008. AS OF JULY 2008, HSBC SECURITIES REPURCHASED MORE THAN 90 PERCENT OF ITS THEN CURRENT CUSTOMERS' ARS HOLDINGS AND IN OCTOBER 2008 OFFERED TO REPURCHASE ALL OF THE REMAINING ARS HELD IN THOSE CUSTOMERS' HSBC SECURITIES ACCOUNTS.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA N.A.
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
COMMODITY EXCHANGE BUSINESS CONDUCT COMMITTEE ("BCC")
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
01/28/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
COMEX 13-9300-BC
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA N.A.
 
6. Principal Product Type:

Other
Other Product Types:
EFRP TRANSACTIONS.
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
COMMODITY EXCHANGE BUSINESS CONDUCT COMMITTEE ("BCC") FOUND THAT ON JANUARY 28, 2013 HSBC BANK USA N.A. ("HSBC") ENTERED INTO TWO EFRP TRANSACTIONS AND ON MAY 30, 2012, HSBC ENTERED INTO ONE EFRP TRANSACTION, IN WHICH HSBC WAS ON BOTH SIDES OF THE TRANSACTIONS. THE PANEL FOUND THAT THE TRANSACTIONS DID NOT CONTAIN DOCUMENTATION OF THE CORRESPONDING CASH POSITIONS AND, THUS, WERE NOT BONA FIDE EFRP TRANSACTIONS. THE PANEL FOUND THAT HSBC VIOLATED NYMEX RULE 538.H AND 534.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
03/20/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 40,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC BANK USA N.A. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE AMOUNT OF $40,000.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, HSBC BANK USA N.A. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE AMOUNT OF $40,000.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
CENSURE AND FINE.
 
3. Date Initiated (MM/DD/YYYY):
09/06/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2009020565101
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
REPORTABLE SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. FAILED TO REPORT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY THE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL, SELL SHORT OR CROSS FOR TRANSACTIONS IN REPORTABLE SECURITIES. FINRA RULE 7230A(D).
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
09/06/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 10,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC SECURITIES (USA) INC. WAS FINED $10,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION, INC. ("NASD")
 
2. Principal Sanction:

Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
12/03/1996 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
CMS960167
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBT CORPORATE, EQUITY OTC, FUTURES FINANCIAL, EQUITY LISTED (COMMON & PREFERRED)
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THAT ON JULY 22,23, 24, 19, AND 31, HSBC ENTERED QUOTATIONS IN THE NASDAQ STOCK MARKET SECURITIE, EXCEEDING THE PARMETERS FOR MAXINUM ALLOWABLE SPREADS PURSUANT TO MARKETPLACE RULE 4613(D).
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
07/11/1997 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 1,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, TO THE ENTRY OF FINDINGS BY NASD REGULATION, INC., HSBC SECURITIES, INC. AGREED TO PAY A FINE OF $1,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
06/19/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
07-MSR-05
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Futures - Financial
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
CHICAGO BOARD OF TRADE ALLEGES THAT HSBC SECURITIES (USA) INC. (A) ENGEGED IN THE EXECUTION OF AN EFP TRANSACTION WITHOUT A BONA FIDE CASH COMPONENT AND (B) THE FIRM EXECUTED TWO CONTINGENT EFP TRANSACTIONS,, IN WHICH THE CASH EXCHAGED CORRELATED TO THE NET OF TWO FUTURES TRANSACTIONS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
09/22/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 30,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC SECURITIES (USA) INC. WAS FINED IN THE AMOUNT OF $30,000. THE FIRM WAS REQUIRED TO PAY ITS FINE WITHIN 30 DAYS OF THE DATE ON WHICH THE DECISION BECAME FINAL.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
IN ORDER TO ENSURE THAT THE TRADING STAFF ("THE STAFF") ARE KNOWLEDGEABLE ABOUT CBOT EFP RULES, THE FIRM HAS IMPLETMENTED AN EFP TRAINING.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE ("CBOT")
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
03/07/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
06-RFT-052
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Futures - Commodity
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 332.08. TRADE DATE FOR THE TRADE DATES OF OCTOBER 1, 2006 THROUGH DECEMBER 27, 2006 REFLECTED AN UNACCEPTABLE CTR ERROR RATE. HSBC WAS FINED $1,000.00.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Other
 
11. Resolution Date (MM/DD/YYYY):
03/08/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 1,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 332.08. TRADE DATE FOR THE TRADE DATES OF OCTOBER 1, 2006 THROUGH DECEMBER 27, 2006 REFLECTED AN UNACCEPTABLE CTR ERROR RATE. HSBC WAS FINED $1,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE ("CBOT")
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
03/14/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
06-MSI-34B
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Futures - Commodity
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 3242.01 IN THAT THE FIRM FAILED TO MAKE DELIVERY OF CONTRACT GRADE TWO-YEAR U.S. TREASURY NOTES BY 1:00 P.M., CHICAGO TIME, ON DELIVERY DAY.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Decision & Order of Offer of Settlement
 
11. Resolution Date (MM/DD/YYYY):
03/14/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 60,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 3242.01 IN THAT THE FIRM FAILED TO MAKE DELIVERY OF CONTRACT GRADE TWO-YEAR U.S. TREASURY NOTES BY 1:00 P.M., CHICAGO TIME, ON DELIVERY DAY. HSBC WAS FINED $60,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ("PANEL")
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
07/25/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
CBOT 11-8572-BC
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
FIVE-YEAR US TREASURY NOTE FUTURES CONTRACTS
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 25, 2014,A PANEL OF THE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON JUNE 3, 2011, HSBC EXECUTED A BLOCK TRADE IN THE SEPTEMBER 2011 FIVE-YEAR US TREASURY NOTE FUTURES CONTRACTS, AND FAILED TO REPORT THE TRADE TO THE EXCHANGE WITHIN FIVE MINUTES. THE PANEL CONCLUDED THAT HSBC THEREBY VIOLATED CBOT RULE 526.F.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
03/27/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 25,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC SECURITIES (USA) INC. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE AMOUNT OF $25,000.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, HSBC SECURITIES (USA) INC. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE AMOUNT OF $25,000.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY FINE
 
3. Date Initiated (MM/DD/YYYY):
05/27/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
FILE NO. 14-0095/ICT#101942
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

No Product
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OPTIONS EXCHANGE, INC.("CBOE"") ALLEGED THAT HSBC SECURITIES (USA) INC.("HSI") VIOLATED EXCHANGE RULE 3.6A, BY FAILING TO REGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER; FAILED TO REGISTER ONE ASSOCIATED PERSON AS A PROPRITARY TRADING PRINCIPAL AND FAILED TO REGISTER FOUR ASSOCIATED PERSONS AS PROPRIETARY TRADERS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Stipulation and Consent
 
11. Resolution Date (MM/DD/YYYY):
09/08/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 17,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $17,500.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO MERCANTILE EXCHANGE
 
2. Principal Sanction:

Other
Other Sanctions:
MONETARY FINE
 
3. Date Initiated (MM/DD/YYYY):
03/04/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
14-7876
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Futures - Commodity
Other Product Types:
FUTURES - FINANCIAL
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC ASSIGNED INCORRECT CUSTOMER TYPE INDICATOR CODES TO FUTURES ACCOUNTS FOR THE PERIOD 12/1/2013 TO 12/31/2013. THIS WAS A VIOLATION OF CME RULE 536.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
03/19/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 5,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC ASSIGNED INCORRECT CUSTOMER TYPE INDICATOR CODES TO FUTURES ACCOUNTS FOR THE PERIOD 12/1 TO 12/31/2013. THIS IS A VIOLATION OF CME RULE 536. AS A RESULT, THE CME IMPOSED A FINE OF $5,000 ON HSBC ON 3/4/2014. HSBC MADE ADJUSTMENTS TO ITS INTERNAL SYSTEM TO CORRECT THE DISCREPANCIES. HSBC PAID THE FINE ON 5/19/2014.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
HSBC ASSIGNED INCORRECT CUSTOMER TYPE INDICATOR CODES TO FUTURES ACCOUNTS FOR THE PERIOD 12/1 TO 12/31/2013. THIS IS A VIOLATION OF CME RULE 536. AS A RESULT, THE CME IMPOSED A FINE OF $5,000 ON HSBC ON 3/4/2014. HSBC MADE ADJUSTMENTS TO ITS INTERNAL SYSTEM TO CORRECT THE DISCREPANCIES. HSBC PAID THE FINE ON 5/19/2014.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO MERCANTILE EXCHANGE AND CHICAGO BOARD OF TRADE
 
2. Principal Sanction:

Other
Other Sanctions:
MONTERY FINE
 
3. Date Initiated (MM/DD/YYYY):
05/08/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
CASE NUMBER 13-7817
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
RECORDKEEPING
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF NOVEMBER 1, 2013 THROUGH JANUARY 31, 2014, HSBC SECUITIES (USA) INC. ("HSBC") VIOLATED RULE 576 BY FAILING TO MAINTAIN ACCURATE AND CURRENT REGISTRATION IN THE EXCHANGE FEE SYSTEM ("EFS"), SUBMITTING ERRONEOUS TAG 50 IDS WITH ORDER MESSAGES, AND SUBMITTING TEST MESSAGES INTO PRODUCTION CME GLOBEX. HSBC ALSO VIOLATED RULE 512 ("REPORTING INFRACTIONS").
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
05/23/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 5,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC PAID $5,000 FINE. THE ALLOCATION OF THE FINE ACROSS BOTH CHICAGO MERCANTILE EXCHANGE AND CHICAGO BOARD OF TRADE IS BASED UPON THE SAME ACTIVITY OCCURRING AT EACH DESIGNATED CONTACT MARKET. (COMPRISED OF $2,500 FOR FAILING TO MAINTAIN ACCURATE AND CURRENT REGISTRATION IN THE EXCHANGE FEE SYSTEM (EFS) AND $2,500 FOR REPORTING INFRACTIONS.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
12/20/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2009019187301
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
TRACE-ELIGIBLE SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED FINRA RULES 2010, 6730(A), NASD RULES 6230(B), 6230(C)(6): - HSBC SECURITIES (USA) INC. FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES; THE FIRM REPORTED INTER-DEALER TRANSACTIONS AS CUSTOMER TRANSACTIONS. THE FIRM FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT. THE FIRM FAILED TO REPORT NUMEROUS TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES TO TRACE WITHIN 15 MINUTES OF THE EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
12/20/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 30,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $30,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
06/01/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2008015436301
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Equity - OTC
Other Product Types:
DESIGNATED SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC")VIOLATED FINRA RULES 6380(A), 6622(B), 7450(A), NASD RULE 6955(A) - HSBC SECURITIES (USA)INC. FAILED TO TIMELY REPORT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS); REPORTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; TRANSMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS TO OATS THAT OATS WAS UNABLE TO LINK TO THE RELATED ORDER ROUTED TO NASDAQ OR THE CORRESPONDING NEW ORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. FINRA ALLEGED THAT HSBC FAILED TO TRANSMIT ROES TO OATS; TRANSMITTED REPORTS TO OATS THAT CONTAINED INACCURATE DESTINATION CODES. HSBC FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) AND FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES TO THE OTC REPORTING FACILITY.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
06/01/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 45,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $45,000.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
09/20/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2010024139801
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
TRACE-ELIGIBLE SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED FINRA RULES 2010, 6730(A), 6760(B), NASD RULE 3010 - HSBC SECURITIES (USA) INC. SERVED AS THE MANAGING UNDERWRITER OF A DISTRIBUTION OR OFFERING, OTHER THAN A SECONDARY OFFERING, AND FAILED TO REPORT SUCH DISTRIBUTION OR OFFERING TO FINRA MARKET OPERATIONS WITHIN THE PRESCRIBED TIME FRAME. HSBC'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND FINRA RULES CONCERNING FINRA RULE 6760(B). FINRA ALLEGED THAT HSBC FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATIONS OF FINRA RULE 2010.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
09/20/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 70,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
UNDERWRITING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $70,000 AND WILL REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FINRA RULE 6760(B) WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
01/07/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2011027202401
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
UNSPECIFIED SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED THE SECURITIES EXCHANGE ACT OF 1934 RULE 17A-4(B)(4), FINRA RULES 2010, 8211, 8213, NASD RULES 2110, 2711(H)(2), 3110, 8211, 8213: THE HSBC'S MIDDLE OFFICE SYSTEM ERRONEOUSLY LEFT OFF SHORT SALE INDICATORS WHEN COMMUNICATING WITH ITS BACK OFFICE SYSTEM, WHICH REPORTED HSBC'S BLUE SHEETS. AS A RESULT, HSBC MISREPORTED SHORT SALE TRANSACTIONS AS LONG SALES ON ITS BLUE SHEETS DURING A FOUR-YEAR PERIOD. HSBC FAILED TO DELIVER PROSPECTUSES OR OFFERING MEMORANDA THAT WERE REQUIRED TO BE DELIVERED IN CONNECTION WITH FIXED INCOME TRANSACTIONS. HSBC EXPERIENCED A BREAKDOWN IN ITS AUTOMATED FEEDS, RESULTING IN FAILURE TO APPEND CERTAIN INVESTMENT BANKING DISCLOSURES TO ITS RESEARCH REPORTS. IN ADDITION, HSBC LEARNED THAT IT HAD ALSO FAILED TO INCLUDE CERTAIN DEBT OFFERINGS IN THE DEFINITION OF INVESTMENT BANKING THAT WAS USED TO DETERMINE THE APPROPRIATE DISCLOSURES FOR ITS RESEARCH REPORTS UP UNTIL THAT TIME. AS A RESULT OF THESE DEFICIENCIES, HSBC ISSUED EQUITY RESEARCH REPORTS WITHOUT REQUIRED DISCLOSURES. MOREOVER, DUE TO INCORRECT MAPPING OF COMPANY IDENTIFIERS, SOME OF THE RESEARCH REPORTS INITIALLY FAILED TO CONTAIN PROPER DISCLOSURES. DESPITE ITS POLICY OF DISABLING TEXT MESSAGING ON EMPLOYEE BLACKBERRIES, CERTAIN NON-TECHNOLOGY EMPLOYEES HAD BLACKBERRIES WITH INBOUND TEXTING FUNCTIONALITY. HSBC LATER TOOK STEPS TO ELIMINATE THIS FUNCTIONALITY. HOWEVER, SOME REGISTERED EMPLOYEES STILL HAD BLACKBERRIES WITH TEXTING CAPABILITY. HSBC FAILED TO RETAIN BLACKBERRY TEXT MESSAGES RECEIVED BY CERTAIN EMPLOYEES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
01/07/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 250,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $250,000. HSBC SATISFIED THE CRITERIA NECESSARY TO RECEIVE CREDIT FOR EXTRAORDINARY COOPERATION. IN LIGHT OF ITS EXTRAORDINARY COOPERATION, HSBC RECEIVED A REDUCED FINE.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
01/15/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2010021555401
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Equity - OTC
Other Product Types:
THRESHOLD SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED SEC RULE 204(A)(2), SEC RULES 200(G), 203(B)(3) OF REGULATION SHO, FINRA RULES 2010, 6624, NASD RULE 3010 - HSBC HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARING AGENCY IN A THRESHOLD SECURITY FOR 13 CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY. HSBC CONTINUED TO HAVE A FAIL-TO-DELIVER POSITION IN THE SECURITY AT THE REGISTERED CLEARING AGENCY ON 79 ADDITIONAL SETTLEMENT DAYS, WHICH FAILED TO CLOSE OUT WHEN REQUIRED. HSBC HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN THE SECURITY THAT RESULTED FROM A SALE OF A SECURITY THAT THE SELLER WAS DEEMED TO OWN PURSUANT TO §242.200 AND INTENDED TO DELIVER ONCE ALL RESTRICTIONS ON DELIVERY HAD BEEN REMOVED, AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE 204(A)(2). HSBC ACCEPTED ORDERS IN DEEMED TO OWN OVER-THE-COUNTER (OTC) EQUITY SECURITIES AND FAILED TO PROPERLY MARK THE ORDERS AS SHORT AND AS A RESULT, HSBC EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO REPORT EACH OF THESE TRANSACTIONS TO THE OTC REPORTING FACILITY WITH A SHORT SALE INDICATOR. HSBC'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND FINRA RULES CONCERNING FINRA RULES 6182 AND 6624 (TRADE REPORTING OF SHORT SALES) AND SEC RULES 200(G)(ORDER MARKING), 203(A) (LONG SALES), 203(B)(1) (LOCATE REQUIREMENT), 203(B)(3) (THRESHOLD CLOSE OUT REQUIREMENT), AND 204 (CLOSE OUT REQUIREMENT).
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
01/15/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 65,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED, FINED $65,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FINRA RULES 6182 AND 6624 (TRADE REPORTING OF SHORT SALES) AND SEC RULES 200(G)(ORDER MARKING), 203(A) (LONG SALES), 203(B)(1) (LOCATE REQUIREMENT), 203(B)(3) (THRESHOLD CLOSE OUT REQUIREMENT), AND 204 (CLOSE OUT REQUIREMENT) WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE.
 
3. Date Initiated (MM/DD/YYYY):
03/19/2008 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
20060059732-01
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
TRACE-ELIGIBLE SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGES THAT HSBC SECURITIES VIOLATED SEC RULE 17A-3, NASD RULES 2110, 6230(A), 6230(C)(8) - FAILURE TO REPORT TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 15 MINUTES OF THE TIME OF EXECUTION; FAILED TO REPORT THE CORRECT TIME OF TRADER EXECUTION FOR TRACE-ELIGIBLE SECURITIES; FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF TRACE-ELIGIBLE SECURITIES ORDERS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
03/19/2008 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 12,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC.("HSBC")WAS CENSURED AND FINED $12, 500.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE.
 
3. Date Initiated (MM/DD/YYYY):
05/14/2008 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2007009471401
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
FIXED INCOME SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGES THAT HSBC SECURITIES (USA) INC. VIOLATED NASD RULES 2110 AND 3010. DURING THE PERIOD JANUARY 2004 THROUGH JUNE 2006, CUSTOMERS WHO MAINATINED ESCROW ACCOUNTS WITH THE FIRM'S BANK AFFILIATE WERE CHARGED COMMISSIONS FOR FIXED INCOME SECURITIES TRADES EXECUTED BY THE FIRM ON THEIR BEHALF, WHICH WERE HIGHER THAN THE COMMISSIONS THEY WERE CHARGED IN THE PAST AND IN CERTAIN INSTANCES, HIGHER THAN INDUSTRY STANDARDS. THE FIRM FAILED TO TAKE ADEQUATE STEPS TO ASSESS THE FAIRNESS OF THE COMMISSIONS. THE FIRM LACKED ADQUATE WRITTEN GUIDELINES FOR MARK-UPS AND COMMISSIONS ON TRADES FOR FIXED INCOME PRODUCTS, AND ALSO FAILED TO ESTABLISH AND MAINTAIN ADQUATE PROCEDURES TO MONITOR THE APPROPRIATENESS OF COMMISSIONS CHARGED THESE CUSTOMERS IN THAT THE FIRM (A) FAILED TO ESTABLISH ADEQUATE WRITTEN GUIDELINES FOR MARK-UPS AND COMMISSIONS ON FIXED INCOME PRODUCTS (B) FAILED TO GIVE ADEQUATE GUIDANCE IN REFERENCE TO DETRMINING WHAT IS A FAIR MARK-UP OR COMMISSION ON FIXED INCOME PRODUCTS (C) FAILED TO INCLUDE TRADES EXECUTED FOR CUSTOMERS IN BRANCH EXAMINATION REVIEWS (D) FAILED TO ESTABLISHED REASONABLE PROCEDURES FOR MONITORING FIXED INCOME SECURITY MARK-UPS AND COMMISSIONS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
05/14/2008 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 200,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. WAS CENSURED AND FINED $200,000.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE.
 
3. Date Initiated (MM/DD/YYYY):
04/30/2009 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2007011232101
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
TRACE-ELIGIBLE SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD RULES 2110, 6230(A) - FINRA ALLEGES THAT HSBC SECURITIES (USA) INC. FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
04/30/2009 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 20,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS,HSBC SECURITIES (USA) INC.CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC SECURITIES (USA)INC. WAS SENSURED AND FINED $20,000.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CENSURE
 
3. Date Initiated (MM/DD/YYYY):
06/10/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2007010582702
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
COLLATERALIZED MORTAGE OBLIGATION ("CMOS")
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MAY 20, 2010, THE FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT IN WHICH HSI, WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO FINDINGS THAT IT: (1) VIOLATED NASD CONDUCT RULES 3010(A) AND (B) AND 2110 BY (A) FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES REGARDING THE SALE OF CMOS TO CUSTOMERS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND WITH FINRA RULES; AND (B) FAILING TO ESTABLISH AND MAINTAIN A SYSTEM OF WRITTEN PROCEDURES REASONABLY DESIGNED TO SUPERVISE WHETHER THE SALES OF CMOS WERE SUITABLE FOR ITS CUSTOMERS AND THE ATTENDED RISKS OF THE PRODUCTS WERE FULLY EXPLAINED WHENEVER A REGISTERED REPRESENTATIVE RECOMMENDED A CMO INVESTMENT; (2) DID NOT COMPLY WITH NASD IM-2210-8 WHICH REQUIRES FIRMS TO OFFER CERTAIN EDUCATIONAL MATERIALS BEFORE THE SALE OF A CMO TO ANY PERSON OTHER THAN AN INSTITUTIONAL INVESTOR AND WHILE THE FIRM DID OFFER A BROCHURE, THE BROCHURE DID NOT COMPLY WITH THE CONTENTS STANDARDS OF NASD CONDUCT RULE 2210(D)(1) AND IM-2210-8; AND (3) VIOLATED NASD CONDUCT RULE 2310 AND 2110 BY RECOMMENDING AND SELLING INVERSE FLOATER CMOS TO CUSTOMERS FOR WHOM SUCH PRODUCTS WERE UNSUITABLE. HSI CONSENTED TO THE IMPOSITION BY FINRA OF A SANCTION OF A CENSURE AND A $375,000 FINE. FINRA ACKNOWLEDGED THAT, INDEPENDENT OF THE IMPOSED SANCTION, IMPACTED CUSTOMERS HAVE RECEIVED FULL RESTITUTION FROM THE FIRM.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
06/10/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 375,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
ON MAY 20, 2010, THE FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT IN WHICH HSI, WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO FINDINGS THAT IT: (1) VIOLATED NASD CONDUCT RULES 3010(A) AND (B) AND 2110 BY (A) FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES REGARDING THE SALE OF CMOS TO CUSTOMERS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND WITH FINRA RULES; AND (B) FAILING TO ESTABLISH AND MAINTAIN A SYSTEM OF WRITTEN PROCEDURES REASONABLY DESIGNED TO SUPERVISE WHETHER THE SALES OF CMOS WERE SUITABLE FOR ITS CUSTOMERS AND THE ATTENDED RISKS OF THE PRODUCTS WERE FULLY EXPLAINED WHENEVER A REGISTERED REPRESENTATIVE RECOMMENDED A CMO INVESTMENT; (2) DID NOT COMPLY WITH NASD IM-2210-8 WHICH REQUIRES FIRMS TO OFFER CERTAIN EDUCATIONAL MATERIALS BEFORE THE SALE OF A CMO TO ANY PERSON OTHER THAN AN INSTITUTIONAL INVESTOR AND WHILE THE FIRM DID OFFER A BROCHURE, THE BROCHURE DID NOT COMPLY WITH THE CONTENTS STANDARDS OF NASD CONDUCT RULE 2210(D)(1) AND IM-2210-8; AND (3) VIOLATED NASD CONDUCT RULE 2310 AND 2110 BY RECOMMENDING AND SELLING INVERSE FLOATER CMOS TO CUSTOMERS FOR WHOM SUCH PRODUCTS WERE UNSUITABLE. HSI CONSENTED TO THE IMPOSITION BY FINRA OF A SANCTION OF A CENSURE AND A $375,000 FINE. FINRA ACKNOWLEDGED THAT, INDEPENDENT OF THE IMPOSED SANCTION, IMPACTED CUSTOMERS HAVE RECEIVED FULL RESTITUTION FROM THE FIRM.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
CENSURED AND FINED.
 
3. Date Initiated (MM/DD/YYYY):
08/19/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2008015260101
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Equity Listed (Common & Preferred Stock)
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED NASD RULES 2110, 4632, 4632(A) 6130(D): THE FIRM FAILED WITHIN 90 SECONDS AFTER EXECUTION TO TRANSMIT TO THE FIRM/NASDAQ TRADE REPORTING FACILITY (FINRA/NASDAQ TRF)105 LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. THE FIRM REPORTED TO THE FINRA/NASDAQ TRF 23 LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO THE FINRA/NASDAQ TRF THE CORRECT TIME OF EXECUTION FOR 79 TRANSACTIONS IN REPORTABLE SECURITIES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
08/19/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 22,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $22,500.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
FINED.
 
3. Date Initiated (MM/DD/YYYY):
08/26/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
FINRA MATTER ID:20130359431
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
NYSE MKT RULE 320. OFFICES - APPROVAL, SUPERVISON AND CONTROL.
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. FAILED TO (I) PROPERLY MONITOR AND RECONCILE DISCREPANCIES WITH ITS CUSTOMER OPTIONS POSITIONS ON FILE AT THE OPTIONS CLEARING CORPORATION ("OCC"), WHICH CAUSED INACCURATE OPEN INTEREST RECORDS FOR 183 BUSINESS DAYS BETWEEN FEBRUARY 24, 2012 AND NOVEMBER 9, 2012, IN ONE INSTANCE, AND FOR 303 BUSINESS DAYS BETWEEN OCTOBER 6, 2011 AND DECEMBER 14, 2012, IN THE SECOND INSTANCE, UNTIL HSBC WAS INSTRUCTED TO EXERCISE THE SUBJECT POSITIONS AND (III) MAINATIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES RELATED TO OCC ADJUSTMENTS AND RECONCILATION PROCESSES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
09/22/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 3,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $3,500.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
02/02/2009 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2007007234501
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
TRACE-ELIGIBLE SECURITIES, MUNICIPAL SECURITIES SUBJECT TO MSRB REPORTING REQUIREMENTS, COVERED OPTIONS CONTRACTS.
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGES THAT HSBC SECURITIES (USA) INC. ("HSBC")VIOLATED ARTICLE VI, SECTION 2 AND SCHEDULE A, SECTION 1 OF THR NASD BY LAWS AND NASD RULE 2110: FAILURE TO INCLUDE TRANSACTIONS FOR CERTAIN COVERED SECURITIES, SUCH AS TRACE-ELIGIBLE SECURITIES, MUNICIPAL SECURITIES SUBJECT TO MSRB REPORTING REQUIREMENTS AND COVERED OPTIONS CONTRACTS, ON ITS TRADING ACTIVITY FEE SELF-REPORTING FORMS FOR CERTAIN ACCOUNTS BETWEEN SEPTEMBER 2003 AND DECEMBER 2006. AS A RESULT, THE REQUIRED TRADING ACTIVITY FEES WERE NOT PAID FOR THESE TRANSACTIONS, SPECIFICALLY, DURING THIS PERIOD HSBC UNDERPAID APPROXIMATELY $28,00.000 IN TRADING ACTIVITY FEES. ONCE THE ERROR WAS DISCOVERED BY HSBC, HSBC SUBSEQUENTLY SUBMITTED CORRECT TRADING ACTIVITY FEE SELF-REPORTING FORMS AND LATER SUBMITTTED AMENDED FORMS AND THE ADDITIONAL FEES TO CORRECT THE PREVIOUS ERRORS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
02/02/2009 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 5,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. WAS FINED $5,000.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
02/26/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2011027541201
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Equity Listed (Common & Preferred Stock)
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULES 5210 AND 2010, NASD RULES 2110 AND 3010. FINRA ALLEGED THAT HSBC ERRONEOUSLY DESIGNATED TWO ACCOUNTS LOCATED IN THE FIRM'S LONDON AFFILIATE TO AUTOMATICALLY TRANSMIT TRADE VOLUME IN U.S.-LISTED SECURITIES TO BLOOMBERG CAUSING HSBC TO OVERSTATE ITS EXECUTED TRADE VOLUME. THE FINDINGS STATED THAT THE HSBC'S SUPERVISORY SYSTEM WITH RESPECT TO THE ADVERTISING OF TRADE VOLUME TO PRIVATE SERVICE PROVIDERS DID NOT PROVIDE FOR SUPERVISION DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR FINRA/NASD RULES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
06/10/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 150,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULES 5210 AND 2010, NASD RULES 2110 AND 3010. FINRA ALLEGED THAT HSBC ERRONEOUSLY DESIGNATED TWO ACCOUNTS LOCATED IN THE FIRM'S LONDON AFFILIATE TO AUTOMATICALLY TRANSMIT TRADE VOLUME IN U.S.-LISTED SECURITIES TO BLOOMBERG CAUSING HSBC TO OVERSTATE ITS EXECUTED TRADE VOLUME. THE FINDINGS STATED THAT THE HSBC'S SUPERVISORY SYSTEM WITH RESPECT TO THE ADVERTISING OF TRADE VOLUME TO PRIVATE SERVICE PROVIDERS DID NOT PROVIDE FOR SUPERVISION DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR FINRA/NASD RULES.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $150,000.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
MONETARY/FINE/CENSURE
 
3. Date Initiated (MM/DD/YYYY):
04/22/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2012033087701
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

No Product
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 7450 AND SEC RULE 10B-10. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTABLE ORDER EVENTS (ROES) THAT WERE REJECTED AND REPAIRABLE. AS A RESULT, HSBC FAILED TO REPAIR ROES DURING A REVIEW PERIOD THAT WERE REJECTED BY THE ORDER AUDIT TRAIL SYSTEM (OATS) FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; FAILED TO REPAIR A PORTION OF THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS; AND FAILED TO POPULATE THE CORRECT REJECTED ROE ID. THE FINDINGS STATED THAT HSBC TRANSMITTED TO OATS ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. HSBC FAILED TO TIMELY REPORT ROES TO OATS; SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS WHICH OATS WAS UNABLE TO LINK TO THE EXECUTION REPORTS TO THE RELATED TRADE REPORTS DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED INFORMATION; SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WHICH OATS WAS UNABLE TO LINK TO THE RELATED ORDER IN THE NEW YORK STOCK EXCHANGE DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WITH INCORRECT DESTINATION CODES; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WHICH OATS WAS UNABLE TO MATCH WITH THE IDENTIFIED RECEIVING FIRM'S RELATED NEW ORDER REPORT; FAILED TO PROPERLY APPEND THE SPECIAL HANDLING CODE OF "CNH" (CASH NOT HELD) TO ORDERS; AND FAILED TO SUBMIT FOR ORDERS A REQUIRED COMBINED ORDER/EXECUTION REPORT TO OATS FOR ORDERS INVOLVING ERROR CORRECTIONS. THE HSBC ALSO FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
06/03/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 22,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 7450 AND SEC RULE 10B-10. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTABLE ORDER EVENTS (ROES) THAT WERE REJECTED AND REPAIRABLE. AS A RESULT, HSBC FAILED TO REPAIR ROES DURING A REVIEW PERIOD THAT WERE REJECTED BY THE ORDER AUDIT TRAIL SYSTEM (OATS) FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; FAILED TO REPAIR A PORTION OF THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS; AND FAILED TO POPULATE THE CORRECT REJECTED ROE ID. THE FINDINGS STATED THAT HSBC TRANSMITTED TO OATS ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. HSBC FAILED TO TIMELY REPORT ROES TO OATS; SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS WHICH OATS WAS UNABLE TO LINK TO THE EXECUTION REPORTS TO THE RELATED TRADE REPORTS DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED INFORMATION; SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WHICH OATS WAS UNABLE TO LINK TO THE RELATED ORDER IN THE NEW YORK STOCK EXCHANGE DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WITH INCORRECT DESTINATION CODES; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WHICH OATS WAS UNABLE TO MATCH WITH THE IDENTIFIED RECEIVING FIRM'S RELATED NEW ORDER REPORT; FAILED TO PROPERLY APPEND THE SPECIAL HANDLING CODE OF "CNH" (CASH NOT HELD) TO ORDERS; AND FAILED TO SUBMIT FOR ORDERS A REQUIRED COMBINED ORDER/EXECUTION REPORT TO OATS FOR ORDERS INVOLVING ERROR CORRECTIONS. THE HSBC ALSO FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC WAS CENSURE AND FINED $22,500(COMPRISED OF $20,000 FOR OATS VIOLATIONS AND $2,500 FOR THE SEC RULE 10B-10 VIOLATIONS).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
N/A
 
3. Date Initiated (MM/DD/YYYY):
01/20/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
20080127719-01
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
NO PRODUCT
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA)INC. ("HSBC") VIOLATED RULE 6955(A): HSBC FAILED TO TIMELY REPORT TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
01/20/2010 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 12,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $12,500.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other
Other Sanctions:
TRACE-ELIGIBLE SECURITIES
 
3. Date Initiated (MM/DD/YYYY):
02/26/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
2012033847501
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
TRACE-ELIGIBLE SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 6730(B)(2) AND FINRA RULE 2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) LARGE BLOCK S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION, FAILED TO REPORT TO TRACE S1 CUSTOMER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT, AND FAILED TO REPORT TO TRACE INTERDEALER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
06/03/2014 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 37,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 6730(B)(2) AND FINRA RULE 2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) LARGE BLOCK S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION, FAILED TO REPORT TO TRACE S1 CUSTOMER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT, AND FAILED TO REPORT TO TRACE INTERDEALER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS,HSBC WAS CENSURED AND FINED $37,500.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
 
2. Principal Sanction:

Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
01/20/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
20120315951
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
EQUITY DERIVATIVES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED NYSE AMEX RULE 980(C) AND NYSE AMEX RULE 320(E). MARKET REGULATION'S REVIEW REVEALED THAT IN VIOLATION OF NYSE AMEX RULE 980(C) HSBC ACCEPTED AND PROCEDDED AN EED TO EXERCISE 750 AT-THE-MONEY BRCM JANUARY 35 CALLS ON EXPIRATION SATURDAY, JANUARY 21, 2012, AFTER THE 5:30 P.M. ET CUTOFF ON FRIDAY JANUARY 20, 2012. FURTHERMORE, A REVIEW OF HSBC'S WRITTEN SUPERVISORY PROCEDURES ("WSPS") FOUND THAT HSBC DID NOT HAVE ADEQUATE PROCESS OR PROCEDURES IN PLACE FOR COMPLIANCE WITH NYSE AMEX RULE 980.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Consent
 
11. Resolution Date (MM/DD/YYYY):
08/07/2012 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 4,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
IN VIOLATION OF THE NYSE AMEX RULE 980(C) HSBC ACCEPTED AND PROCESSED CONTRARY EXERCISE INSTRUCTIONS TO EXERCISE 750 AT-THE-MONEY BRCM JANUARY 35 CALLS ON EXPIRATION SATURADAY, JANUARY 21, 2012, RECEIVED AFTER THE 5:30 P.M. ET CUTOFF ON FRIDAY JANUARY 20, 2012. HSBC CONSENT TO PAY A FINE OF $1,000. IN VIOLATION OF THE NYSE AMEX RULE 320(E) A REVIEW OF HSBC'S WRITTEN SUPERVISORY PROCEDURES ("WSP") FOUND THAT HSBC DID NOT HAVE ADEQUATE PROCESS OR PROCEDURES IN PLACE FOR COMPLIANCE WITH NYSE AMEX RULE 980.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
IN VIEW OF THE FOREGOING MARKET REGULATION, HSBC WAS ISSUED A FINE FOR MINOR VIOLATION OF RULES DATED AUGUST 7, 2012 IN THE TOTAL AMOUNT OF $4,500 PURSUANT TO NYSE MKT RULE 476A (IMPOSITION OF FINES FOR MINOR VIOLATION OF RULES) $1,000 FOR HSBC'S VIOLATION OF NYSE AMEX OPTIONS RULE 980(C) AND #3,500 FOR VIOLATING NYSE AMEX RULE 320(E).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION INC. ("NASD")
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
07/27/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
20050026982-01
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
NO PRODUCT TYPE
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD REGULATION INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED NASD RULE 2110 - RESPONDENT MEMBER FAILED WITHIN 90 SECONDS AFTER EXECUTION TO TRANSMIT TO THE NASDAQ MARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTION IN CQS SECURITIES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
07/27/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 5,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
THE NASD REGULATION INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED NASD RULE 2110 - RESPONDENT MEMBER FAILED WITHIN 90 SECONDS AFTER EXECUTION TO TRANSMIT TO THE NASDAQ MARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTION IN CQS SECURITIES.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC SECURITIES (USA) INC. WAS FINED $5,000.00.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION, INC.
 
2. Principal Sanction:

Censure
Other Sanctions:
MONETARY/FINE
 
3. Date Initiated (MM/DD/YYYY):
06/12/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
20060055677-01
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Equity - OTC
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THE FOLLOWING: SEC RULES 10B-10, 17A-3, A7A-4, 200(G) OF REGULATION SHO, 203(B)(1) OF REGULATION SHO, NASD RULES 3010, 3110, 6130, 6955(A) - HSBC SECURITIES (USA) INC. ("HSBC") ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR AFFECTED A SHORT SALE IN AN EQUITY SECURITYFOR ITS OWN ACCOUNT, WITHOUT DOCUMENTING THAT IT BORROWED THE SECURITY, OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY, OR THAT IT HAD REASONABLE GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE. THE FINDINGS STATED THAT THE FIRM FAILED TO CORRECTLY REPORT SALE TRANSACTIONS TO ACT AS LONG, SHORT OR SHORT EXEMPT, FAILED TO REPORT THE CORRECT EXECUTION TIME AND IN ONE INSTANCE, THE FIRM REPORTED ITS CAPACITY AS PRINCIPAL WHEN IT WAS ACTING AS AGENT. THE FINDINGS ALSO STATED THAT THE FIRM REPORTED TO OATS EXECUTION REPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA AND EXECUTED SHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDER TICKETS AS SHORT FOR THESE ORDERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREE YEARS, THE FIRST TWO IN AN ACCESSIBLE PLACE, THE MEMORANDUM OF BROKERAGE ORDERS, A CUSTOMER CONFIRMATION AND FAILED TO SHOW THE TIME OF RECEIPT ON THE MEMORANDUM OF A BROKERAGE ORDER. THE NASD FOUND THAT THE FIRM FAILED TO DISCLOSE THE CORRECT CAPACITY AND TO DISCLOSE AVERAGE PRICE ON CUSTOMER CONFIRMATIONS. THE NASD ALSO FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES RELATING TO COMPLIANCE WITH ORDER HANDLING, BEST EXECUTION, ANTI-INTIMIDATION AND COORDINATION, SALES TRANSACTIONS, BOOKS AND RECORDS AND FOR MONITORING USE OF FIRM'S BANK.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
06/12/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 27,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. ("HSBC"), CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $27,500.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE NASD ALLEGED THE FOLLOWING: SEC RULES 10B-10, 17A-3, A7A-4, 200(G) OF REGULATION SHO, 203(B)(1) OF REGULATION SHO, NASD RULES 3010, 3110, 6130, 6955(A) - HSBC SECURITIES (USA) INC. ("HSBC") ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR AFFECTED A SHORT SALE IN AN EQUITY SECURITYFOR ITS OWN ACCOUNT, WITHOUT DOCUMENTING THAT IT BORROWED THE SECURITY, OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY, OR THAT IT HAD REASONABLE GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE. THE FINDINGS STATED THAT THE FIRM FAILED TO CORRECTLY REPORT SALE TRANSACTIONS TO ACT AS LONG, SHORT OR SHORT EXEMPT, FAILED TO REPORT THE CORRECT EXECUTION TIME AND IN ONE INSTANCE, THE FIRM REPORTED ITS CAPACITY AS PRINCIPAL WHEN IT WAS ACTING AS AGENT. THE FINDINGS ALSO STATED THAT THE FIRM REPORTED TO OATS EXECUTION REPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA AND EXECUTED SHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDER TICKETS AS SHORT FOR THESE ORDERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREE YEARS, THE FIRST TWO IN AN ACCESSIBLE PLACE, THE MEMORANDUM OF BROKERAGE ORDERS, A CUSTOMER CONFIRMATION AND FAILED TO SHOW THE TIME OF RECEIPT ON THE MEMORANDUM OF A BROKERAGE ORDER. THE NASD FOUND THAT THE FIRM FAILED TO DISCLOSE THE CORRECT CAPACITY AND TO DISCLOSE AVERAGE PRICE ON CUSTOMER CONFIRMATIONS. THE NASD ALSO FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES RELATING TO COMPLIANCE WITH ORDER HANDLING, BEST EXECUTION, ANTI-INTIMIDATION AND COORDINATION, SALES TRANSACTIONS, BOOKS AND RECORDS AND FOR MONITORING USE OF FIRM'S BANK.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION, INC.
 
2. Principal Sanction:

Other
Other Sanctions:
MONETARY SANCTION
 
3. Date Initiated (MM/DD/YYYY):
03/02/2001 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
COMPLAINT NUMBER CMS 020140
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Equity - OTC
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
34 BACKING AWAY INCIDENTS DURING THE FOURTH QUARTER OF 2000.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
08/06/2002 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 10,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
FINED $10,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NEW YORK STOCK EXCHANGE REGULATION - DIVISION OF ENFORCEMENT
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CENSURE AND UNDERTAKING
 
3. Date Initiated (MM/DD/YYYY):
07/27/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
NYSE HEARING BOARD DECISION 07-150
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
CALLABLE RANGE ACCRUAL CERTIFICATES OF DEPOSIT.
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
(1) VIOLATION OF NYSE RULE 476(A)(6) FOR ENGAGING IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE BY: (A) RECOMMENDING AND SELLING LIBOR CDS TO CUSTOMERS FOR WHOM SUCH PRODUCTS WERE UNSUITABLE; (B) FAILING TO ACCURATELY ADVISE CUSTOMERS ABOUT THE RISKS ASSOCIATED WITH THE LIBOR CDS; AND/OR (C) MAKING MATERIAL MISREPRESENTATIONS REGARDING CERTAIN MATERIAL FEATURES OF THE LIBOR CDS AND/OR THE MANNER IN WHICH THE PRODUCTS WERE LIKELY TO PERFORM. (2) VIOLATION OF NYSE RULE 401(A) BY FAILING TO ADHERE TO PRINCIPLES OF GOOD BUSINESS PRACTICE BY RECOMMENDING AND SELLING THE LIBOR CD PRODUCTS TO CLIENTS FOR WHOM THEY WERE NOT SUITABLE. (3) VIOLATION OF NYSE RULE 342(A) AND (B) BY: (A) FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES TO REASONABLY SUPERVISE WHETHER THE SALE OF CALLABLE LIBOR CDS WERE SUITABLE FOR ITS CUSTOMERS, AND (B) FAILING TO ADEQUATELY SUPERVISE ITS PERSONNEL IN ORDER TO REASONABLY DETECT AND PREVENT MISREPRESENTATIONS REGARDING MATERIAL FEATURES OF LIBOR CDS, AND/OR THE MANNER IN WHICH THEY WERE LIKELY TO PERFORM.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Stipulation and Consent
 
11. Resolution Date (MM/DD/YYYY):
10/08/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 500,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
THE FIRM MUST ENGAGE IN AN UNDERTAKING REQUIRING THE FIRM TO REVIEW THE PURCHASES OF THE OUTSTANDING LIBOR CDS (THAT EXISTED AS OF JUNE 1, 2007) AND OFFER A REMEDIATION PLAN REVIEWED AND APPROVED BY NYSE ENFORCEMENT, IN ACCORDANCE WITH THE TERMS OF THE STIPULATION AND CONSENT TO PENALTY.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
CENSURE AND FINE IN THE AMOUNT OF $500,000 AND AN UNDERTAKING REQUIRING THE FIRM TO REVIEW THE PURCHASES OF THE OUTSTANDING LIBOR CDS (THAT EXISTED AS OF JUNE 1, 2007) AND OFFERA REMEDIATION PLAN, REVIEWED AND APPROVED BY NYSE ENFORCEMENT, IN ACCORDANCE WITH THE TERMS OF THE STIPULATION AND COSENT TO PENALTY.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE NYSE HEARING BOARD RENDERED A DECISION ON SEPTEMBER13, 2007 WITH REGARD TO THE STIPULATION OF FACTS AND CONSENT TO PENALTY ENTERED INTO BETWEEN THE FIRM AND THE DIVISION OF ENFORCEMENT OF NYSE REGULATION. THE DECISION BECAME FINAL AT THE CLOSE OF BUSINESS ON OCTOBER 8, 2007. THE FIRM MUST OFFER ITS REMEDIATION PLAN TO NYSE ENFORCEMENT WITHIN 30 DAYS OF THE THE DATE ON WHICH THE DECISION BECAME FINAL. THE FIRM IS REQUIRED TO PAY ITS FINE WITHIN 45 DAYS OF THE DATE ON WHICH THE DECISION BECAME FINAL.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button selected, changed INITIAL OR Radio button not selected AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox checked, changed 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button selected, changed You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA, NATIONAL ASSOCIATION
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button selected, changedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
EUROPEAN COMMISSION, THE DIRECTOR-GENERAL COMPETITION
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
DISGORGEMENT/CEASE AND DESIST
 
3. Date Initiated (MM/DD/YYYY):
07/01/2013 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
CASE AT.39745
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA, N.A.
 
6. Principal Product Type:

Other
Other Product Types:
CREDIT DEFAULT SWAPS AND CREDIT DERIVATIVES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATEMENT OF OBJECTIONS IS ADDRESSED TO BANK OF AMERICA MERRILL LYNCH, BARCLAYS, BEAR STEARNS, BNP PARIBAS, CITIGROUP, CREDIT SUISSE, DEUTSCHE BANK, GOLDMAN SACHS, HSBC, JP MORGAN, MORGAN STANLEY, ROYAL BANK OF SCOTLAND, UBS AS WELL AS THE INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION (ISDA) AND DATA SERVICE PROVIDER MARKIT. THE COMMISSION ALLEGES THAT BETWEEN 2006 AND 2009, DEUTSCHE BÖRSE AND THE CHICAGO MERCANTILE EXCHANGE TRIED TO ENTER THE CREDIT DERIVATIVES BUSINESS. THE EXCHANGES ALLEGEDLY TURNED TO ISDA AND MARKIT TO OBTAIN NECESSARY LICENSES FOR DATA AND INDEX BENCHMARKS, BUT, ACCORDING TO THE PRELIMINARY FINDINGS OF THE COMMISSION, THE BANKS CONTROLLING THESE BODIES INSTRUCTED THEM TO LICENSE ONLY FOR "OVER-THE-COUNTER" (OTC) TRADING PURPOSES AND NOT FOR EXCHANGE TRADING. ALLEGEDLY, SEVERAL OF THE INVESTMENT BANKS ALSO SOUGHT TO SHUT OUT EXCHANGES IN OTHER WAYS, FOR EXAMPLE BY COORDINATING THE CHOICE OF THEIR PREFERRED CLEARING HOUSE. THE STATEMENT OF OBJECTIONS SEEKS FINES IN AN AMOUNT TO BE DETERMINED BY THE COMMISSION AS WELL AS IMPOSITION OF A CEASE AND DESIST ORDER.
 
8. Current Status?      Radio button selected, changed  Pending     Radio button not selected  On Appeal     Radio button not selected  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:
 
11. Resolution Date (MM/DD/YYYY):
Radio button not selected  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox not checked  Monetary/Fine Amount: $
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox checked, changed 11.D(2) Checkbox not checked 11.D(3) Checkbox checked, changed 11.D(4) Checkbox checked, changed 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button selected, changed One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: REPUBLIC NEW YORK SECURITIES CORPORATION ("RNYSC")
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UNITED STATES ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK
 
2. Principal Sanction:

Revocation
Other Sanctions:
IN JANUARY, 2002,THE COURT ENTERED A JUDGEMENT AND SENTENCED RNYSC TO AN ORDER OF RESTITUTION TO VARIOUS INVESTORS TOTALING $606 MILLION.
 
3. Date Initiated (MM/DD/YYYY):
08/01/1999 Radio button not selected  Exact   Radio button selected, changed  Explanation
If not exact, provide explanation:
DATE INITIATED IS AN APPROXIMATE DATE.
 
4. Docket/Case Number:
FILE NO. 3-10653
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Futures - Financial
Other Product Types:
SECURITIES
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
PURSUANT TO A PLEA AGREEMENT ENTERED INTO WITH THE UNITED STATES ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF NEW YORK, REPUBLIC NEW YORK SECURITIES CORPORATION ("RNYSC") PLEADED GUILTY IN DECEMBER, 2001 TO A TWO-COUNT FELONY INFORMATION CHARGING ONE COUNT OF CONSPIRACY TO VIOLATE THE FEDERAL SECURITIES AND COMMODITIES LAWS AND ONE COUNT OF VIOLATION OF THE SECURITIES LAWS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
12/17/2001 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox not checked  Monetary/Fine Amount: $
Checkbox checked, changed  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
"RNYSC" AGREED TO PAY $606 MILLION IN RESTITUTION.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
IN CONJUNCTION WITH ITS GUILTY PLEA, "RNYSC" ALSO ENTERED INTO AGREEMENTS WITH EACH OF THE SECURITIES AND EXCHANGE COMMISSION AND THE COMMODITIES FUTURES TRADING COMMISSION UNDER WHICH THOSE AGENCIES ISSUED ADMINISTRATIVE ORDERS REVOKING THE LICENSES THEY HAD PREVIOUSLY GRANTED TO "RNYSC",AND IN THE CASE OF THE CFTC IMPOSING A CIVIL MONETARY PENALTY. SEPARATELY, THE COMMISSION ISSUED A TEMPORARY ORDER EXEMPTING "RNYSC'S" NEW PARENT HSBC, AS WELL AS HSBC ASSET MANAGEMENT FROM THE PROVISIONS OF SECTION 9(A) OF THE INVESTMENT COMPANY ACT. "RNYSC" IS A DORMANT COMPANY AND NO LONGER CONDUCTS ACTIVITIES.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox checked, changed 11.D(2) Checkbox not checked 11.D(3) Checkbox checked, changed 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox not checked 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button selected, changedState   Radio button not selected SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF WISCONSIN (COMMISSIONER OF SECURITIES)
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
06/25/1996 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
S-96053(L)
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBT CORPORATE, EQUITY-OTC, FUTURES-FINANCIAL, EQUITY LISTED(COMMON & PREFERRED STOCK)
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATION OF SECTION 551.63. OF THE WISCONSIN STATUES.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
07/24/1996 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 4,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
HSBC SECURITIES (USA) INC. WAS ORDERED TO PAY $4,000.00 AS AN ADMINISTRATIVE ASSESSMENT PURSUANT TO SECTION 551.605 OF THE WISCONSIN STATUES.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button not selected You (the advisory firm)
Radio button selected, changed You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number: This advisory affiliate is Radio button selected, changed a Firm   Radio button not selected an Individual  
Registered: Radio button not selected Yes   Radio button selected, changed No    
Name: HSBC BANK USA NATIONAL ASSOCIATION ("HSBC")
(For individuals, Last, First, Middle) 		 

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
THE BUSINESS CONDUCT COMMITTEE OF THE NEW YORK MERCANTILE EXCHANGE, INC.
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
DISGOEGEMENT
 
3. Date Initiated (MM/DD/YYYY):
08/24/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
11-08131-BC
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA NATIONAL ASSOCIATION ("HSBC")
 
6. Principal Product Type:

Futures - Commodity
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEW YORK MERCANTILE EXCHANGE, INC. ALLEGED THAT ON JANUARY 31, 2011, A DATE SUBJECT TO A SPOT MONTH SPECULATIVE POSITION LIMIT FOR THE FEBRUARY 2011 GOLD FUTURES CONTRACT, HSBC INADVERTENTLY MAINTAINED A LONG GOLD FUTURES POSITION THAT EXCEEDED THE APPROVED EXPIRATION MONTH HEDGE EXEMPTION OF 5,000 CONTRACTS GRANTED BY THE EXCHANGE ON AUGUST 11, 2010, BY 153 CONTRACTS (3%). UPON BEING INFORMED OF THE EXCESSIVE POSITION, THE NEW YORK MERCANTILE EXCHANGE, INC. ALLEGED THAT HSBC IMMEDIATELY LIQUIDATED ITS OVERAGE POSITION RESULTING IN PROFITS OF $7,250. THE PANEL FOUND THAT IN SO DOING, HSBC VIOLATED COMEX RULE 562.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Decision & Order of Offer of Settlement
 
11. Resolution Date (MM/DD/YYYY):
08/26/2011 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 17,250
Checkbox not checked  Revocation/Expulsion/Denial Checkbox checked, changed  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
IN ACCORDANCE WITH THE SETTLEMENT OFFER AND IT FINDINGS, THE BCC PANEL ORDERED HSBC TO PAY THE EXCHANGE IN THE AMOUNT OF $10,000 AND DISGORGE $7,250 IN PROFITS.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC ACCEPTED AN OFFER OF SETTLEMENT FOR $17,250.00.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE ("CBOT")
 
2. Principal Sanction:

Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
04/06/1998 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
98-INV-4A
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBT CORPORATE, EQUITY OTC, FUTURES FINANCIAL, EQUITY LISTED (COMMON & PREFERRED STOCK)
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATION OF REGULATION 9B.16, BY VITUE OF REGULATION 9B.07 IN THAT PROJECT A TERMINAL OPERATORS EMPLOYED BY HSBC KNOWINGLY CAUSED TRANSACTIONS TO BE ENTERED INTO THE PROJECT A SYSTEM IN WHICH A PROPRIETARY ACCOUNT ASSUME THE OPPOSITE SIDE OF CUSTOMER ORDERS AND THE PROPRIETARY ORDERS WERE ENTERED PRIOR TO THE ORDERS; AND RULE 504.00, IN THAT, BY VIRTUE OF THE ABOVE-REFERENCE VIOLATION.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
02/26/1999 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 20,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION OF REGULATION 9B.16 AND RULE 504.00, AS CITED IN THE PRELIMINARY CHANGES, HSBC AGREED TO PAY A FINE OF $20,000 IN SETTLEMENT OF THIS MATTER.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE ("CBOT")
 
2. Principal Sanction:

Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
12/01/1998 Radio button not selected  Exact   Radio button selected, changed  Explanation
If not exact, provide explanation:
DATE INITIATED IS AN APPROXIMATE DATE.
 
4. Docket/Case Number:
98-RFT-187
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Futures - Financial
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CBOT ALLEGATED THAT HSBC VIOLATED REGULATION 332.08 IN THAT THE FIRM FAILED TO MAKE ALL TRADE DATA SUBMISSIONS IN A CORRECT MANNER.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
03/01/1999 Radio button not selected  Exact   Radio button selected, changed  Explanation
If not exact, provide explanation:
RESOLUTION DATE IS AN APPROXIMATE DATE.
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS ORDERED TO PAY A FINE IN THE AMOUNT OF $500.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION INC. ("NASD")
 
2. Principal Sanction:

Censure
Other Sanctions:
FINED; DISGORGEMENT/RESTITUTION; UNDERTAKING.
 
3. Date Initiated (MM/DD/YYYY):
01/17/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
20050001900
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBT - MUNICIPAL;DEBT - CORPORATE; EQUITY - OTC; EQUITY LISTED (COMMON & PREFERRED STOCK); FUTURES - FINANCIAL; INSURANCE
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD REGULATION, INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. F/K/A HSBC BROKERAGE (USA) INC. VIOLATED RULE G-30 AND SUPERVISION VIOLATION OF RULE G-27.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
01/17/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 17,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox checked, changed  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. WAS CENSURED AND FINED $17,500.00, REQUIRED TO PAY $1329.53, PLUS INTEREST, IN RESTITUTION TO PUBLIC CUSTOMERS AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FAIR PRICING AND MARKUPS WITHIN THIRTY (30) DAYS OF ACCEPTANCE OF THIS AWC BY NAC. A REGISTERED PRINCIPAL OF THE FIRM WILL SUBMIT SATISFACTORY PROFF OF PAYMENT OF THE RESTITUTION OT OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO NASD NO LATER THAN 60 DAYS AFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTED RESTITUTION AND INTEREST WILL BE FORWARDED TO THE APPROPRIATE ECCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LAST RESIDED.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION, INC. ("NASD")
 
2. Principal Sanction:

Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
03/17/1999 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
C8A990038-AWC
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBT CORPORATE, EQUITY-OTC, FUTURES-FINANCIAL, EQUITY LISTED(COMMON & PREFERRED STOCK)
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD REGULATION, INC. ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED: MARKETPLACE RULES 4632(A), 4620(A)AND 4642(A): MARKETPLACE RULES 4632(A), 6420(A) AND 4642(A); MARKETPLACE RULES 6130(D); CONDUCT RULE 3370; CONDUCT RULE 3360; CONDUCT RULE 2110; CONDUCT RULES 2110 AND 301(B).
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
05/03/1999 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 7,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $7,500.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION. INC.
 
2. Principal Sanction:

Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
03/13/1998 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
MRD 199801874
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBT CORPORATE, EQUITY-OTC, FUTURES-FINANCIAL, EQUITY LISTED (COMMON & PREFERRED STOCK)
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC VIOLATED SECURITIES EXCHANGE ACT RULE 11AC1-1 ("SEC FIRM QUOTE RULE"), NASD CONDUCT RULE 3320 AND NASD MARKETPLACE RULE 4613 (B) ("NASD FIRM QUOTE RULES"). VIOLATION OF NASD CONDUCT RULES 2110 AND 3010. FAILURE TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERN THE SEC AND NASD FIRM QUOTE RULES. A CENSURE, A FINE OF $8,000 ($5,000 FOR THE FIRM QUOTE RULE VIOLATION AND $3,000 FOR THE SUPERVISION VIOLATION).
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Settled
 
11. Resolution Date (MM/DD/YYYY):
10/19/1998 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 8,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION OF SEC RULE 11AC1-1, RULE 3320, RULE 4613(B) RULES 2110 AND 3010, AS CITED BY THE NASD REGULATION, INC. HSBC AGREED TO PAY A FINE OF $8,000 IN SETTLEMENT OF THIS MATTER.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button selected, changed  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NEW YORK STOCK EXCHANGE, INC. ("NYSE")
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
01/21/1998 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
99-24
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBT CORPORATE, EQUITY-OTC, FUTURES-FINANCIAL, EQUITY LISTED (COMMON & PREFERRED STOCK)
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NYSE ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED SEC RULE 17A-3 (AND 17A-4) AND EXCHANGE RULE 440 - FILURE TO KEEPBOOKS AND RECORDS CURRENT. VIOLATION OF SEC RULE 17A-11; SEC RULE 15C3-3; RULE 15C3-3(D)(1); SECTION 220(B)(2) OF REGULATION T; EXCHANGE RULE 410(B); EXCHANGE RULE 132; EXCHANGE RULE 345 AND 345.10; EXCHANGE RULE 342 AND 346. CENSURED AND FINED $50,000.00.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
03/17/1999 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 50,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC HAS TAKEN CORRECTIVE ACTION IN THIS MATTER AND AGREED TO PAY A FINE OF $50,000.00.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NEW YORK STOCK EXCHANGE, INC.
 
2. Principal Sanction:

Censure
Other Sanctions:
FINE
 
3. Date Initiated (MM/DD/YYYY):
10/29/2003 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
04-190
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
E:MAIL RETENTION
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO PRESERVE ELECTRONIC COMMUNICATION FOR A PERIOD OF THREE YEARS. FAILURE TO REASONABLY SUPERVISE OPERATIONAL AND TECHNOLOGICAL ACTIVES RELATING TO RETENTION OF ELECTRONIC COMMUNICATIONS. NOT PROMPTLY REPORTING FAILURE TO RETAIN ELECTRONIC COMMUNICATIONS.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Stipulation and Consent
 
11. Resolution Date (MM/DD/YYYY):
12/15/2004 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 500,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
FINED $500,000.00. RESOLUTION DATE: 12/15/2004.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE ("CBOT")
 
2. Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
 
3. Date Initiated (MM/DD/YYYY):
11/01/2005 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
05-RFT-058
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Futures - Commodity
Other Product Types:
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC.("HSBC") VIOLATED REGULATION 332.08. TRADE DATES FOR THE PERIOD OF NOVEMBER 1, 2005 THROUGH DECEMBER 31, 2005 AND FOR THE PERIOD OF FEBRUARY 27, 2006 THROUGH MARCH 24, 2006 CONTAINED AT LEASE ONE DATA ENTRY ERROR.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Other
 
11. Resolution Date (MM/DD/YYYY):
08/03/2006 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 1,800
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC.("HSBC") VIOLATED REGULATION 332.08. TRADE DATES FOR THE PERIOD OF NOVEMBER 1, 2005 THROUGH DECEMBER 31, 2005 AND FOR THE PERIOD OF FEBRUARY 27, 2006 THROUGH MARCH 24, 2006 CONTAINED AT LEASE ONE DATA ENTRY ERROR. HSBC WAS FINED $1800,00
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC.("HSBC") VIOLATED REGULATION 332.08. TRADE DATES FOR THE PERIOD OF NOVEMBER 1, 2005 THROUGH DECEMBER 31, 2005 AND FOR THE PERIOD OF FEBRUARY 27, 2006 THROUGH MARCH 24, 2006 CONTAINED AT LEASE ONE DATA ENTRY ERROR. HSBC WAS FINED $1800,00
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION INC. ("NASD")
 
2. Principal Sanction:

Other
Other Sanctions:
FINED.
 
3. Date Initiated (MM/DD/YYYY):
03/13/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
4. Docket/Case Number:
20041000233-01
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
 
6. Principal Product Type:

Other
Other Product Types:
NO PRODUCT.
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD REGULATION INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED: NASD RULE 3360 FOR FAILURE TO TIMELY REPORT ITS SHORT INTEREST POSITIONS TO THE NASD.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
03/13/2007 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 5,000
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox not checked  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
THE NASD REGULATION INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED: NASD RULE 3360 FOR FAILURE TO TIMELY REPORT ITS SHORT INTEREST POSITIONS TO THE NASD.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC SECURITIES (USA) INC. WAS FINED $5,000.00.
 


GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an Radio button not selected INITIAL OR Radio button selected, changed AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
 
Regulatory Action
Check item(s) being responded to:
Checkbox not checked 11.C(1) Checkbox not checked 11.C(2) Checkbox not checked 11.C(3) Checkbox not checked 11.C(4) Checkbox not checked 11.C(5)
Checkbox not checked 11.D(1) Checkbox not checked 11.D(2) Checkbox not checked 11.D(3) Checkbox not checked 11.D(4) Checkbox not checked 11.D(5)
Checkbox not checked 11.E(1) Checkbox checked, changed 11.E(2) Checkbox not checked 11.E(3) Checkbox not checked 11.E(4)
Checkbox not checked 11.F. Checkbox not checked 11.G.
 
 
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details to each action on a separate DRP.
 
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
Radio button selected, changed You (the advisory firm)
Radio button not selected You and one or more of your advisory affiliates
Radio button not selected One or more of your advisory affiliates
 
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

Checkbox not checked This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
Checkbox not checked This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
 
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
 
Checkbox not checked This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
 
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Radio button not selected  Yes    Radio button not selected  No
 
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
 
PART II
1.   Regulatory Action initiated by:
Radio button not selectedSEC   Radio button not selectedOther Federal   Radio button not selectedState   Radio button selected, changed SRO   Radio button not selectedForeign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NASD REGULATION, INC.
 
2. Principal Sanction:

Censure
Other Sanctions:
A FINE OF $7,500.
 
3. Date Initiated (MM/DD/YYYY):
07/01/2003 Radio button not selected  Exact   Radio button selected, changed  Explanation
If not exact, provide explanation:
THE EXACT DATE WAS NOT PROVIDED.
 
4. Docket/Case Number:
CONSENT NO. C10030122
 
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
 
6. Principal Product Type:

Debt - Government
Other Product Types:
DEBIT - CORPORATE DEBIT - ASSET BACKED EQUITY - OTC FUTURES - COMMODITY
 
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ALLEGATIONS RELATED TO THIS REGULATORY ACTION IS AS FOLLOWS: 1) DURING THE TIME PERIOD NOVEMBER 6, 2002 TO JANUARY 22, 2003, HSBC SECURITIES INACCURATELY REPORTED TO THE TRADE REPORTING A COMPLIANCE ENGINE ("TRACE") THAT IT HAD ACTED AS AN AGENT, WHEN IT HAD ACTUALLY ACTED IN A PRINCIPAL CAPACITY, IN 60 RANDOM TRANSACTIONS REVIEWED BY NASD STAFF. BY REASON OF THE FOREGOING, HSBC SECURITIES VIOLATED NASD MARKETPLACE RULE 6230 AND NASD CONDUCT RULE 2110. 2) DURING THE TIME PERIOD JULY 2002 TO JANUARY 2003, HSBC SECURITIES FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH TRACE REPORTING REQUIREMENTS. BY REASON OF FOREGOING, HSBC SECURITIES VIOLATED NASD CONDUCT RULE 3010(A) AND NASD CONDUCT RULE 2110.
 
8. Current Status?      Radio button not selected  Pending     Radio button not selected  On Appeal     Radio button selected, changed  Final    
 
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
 
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
 
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
 
11. Resolution Date (MM/DD/YYYY):
12/18/2003 Radio button selected, changed  Exact   Radio button not selected  Explanation
If not exact, provide explanation:
 
12. Resolution Detail:
A.   Were any of the following Sanctions Ordered (check all appropriate items)?
Checkbox checked, changed  Monetary/Fine Amount: $ 7,500
Checkbox not checked  Revocation/Expulsion/Denial Checkbox not checked  Disgorgement/Restitution
Checkbox checked, changed  Censure Checkbox not checked  Cease and Desist/Injunction
Checkbox not checked  Bar Checkbox not checked  Suspension
B. Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate date paid and if any portion of penalty was waived:
WITH RESPECT TO THE FINDING LISTED IN THE AWC, PLEASE NOTE THAT THIS WAS CAUSED BY A PROGRAMMING ERROR RESULTING FROM HSBC SECURITIES (USA) INC. STAFF DEFAULTING TO THE WRONG CAPACITY DESIGNATION WHEN THE FOIRM'S TRACE REPORTING SOFTWARE WAS FIRST IMPLEMENTED. THIS ISSUE WAS IMMEDIATELY RESOLVED WHEN IT WAS BROUGHT TO OUR ATTENTION. WITH RESPECT TO FINDING LISTED IN THE AWC, THIS WAS ALSO RESOLVED DURING THE 2003 EXAMINATION OF OUR FIRM. REVISED PROCEDURES WERE PREPARED AND GIVEN TO THE NASD EXAMINER WHO CONDUCTED THE REVIEW. THESE PROCEDURES INCLUDE, AMOUNG OTHER THINGS, REVIEWING TRANSACTIONS BY UTILIZING THE "TRADE REPORTING SYSTEM" FUNCTION OF THE TRACE WEB SITE. HSBC SECURITIES WAS FINED $7,500.00. PAYMENT WAS MADE BY BANK CHECK TO THE NASD FOR THE FULL AMOUNT EFFECTIVE JANUARY 15, 2004.
 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
PER THE NASD FINDINGS, DURING THE PERIOD OF NOVEMBER 6, 2002 AND JANUARY 22, 2003, HSBC SECURITIES INACCURATELY REPORTED TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") THAT IT HAD ACTED AS A AGENT, WHEN IT HAD ACTUALLY ACTED IN A PRINCIPAL CAPACITY. DURING THE TIME PERIOD JULY 2002 TO JANUARY 2003, HSBC SECURITIES FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH TRACE REPORTING REQUIREMENT. HSBC SECURITIES ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS WAS CENSURED AND FINED $7,500.00. WITH RESPECT TO THE INACCURACY REPORTED TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE"), THIS WAS CAUSED BY A PROGRAMMING ERROR RESULTING FROM HSBC SECURITIES (USA) INC. STAFF DEFAULTING TO THE WRONG CAPACITY DESIGNED WHEN THE FIRM'S TRACE REPORTING SOFTWARE WAS FIRST IMPLEMENTED. THIS ISSUE WAS IMMEDIATELY RESOLVED WHEN IT WAS BROUGHT TO OUR ATTENTION. WITH RESPECT TO FAILURE TO ESTABLISH AND MAINTAIN AND ADEQUATE SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH TRACE REPORTING REQUIREMENT, THIS ISSUE WAS ALSO RESLOVED DURING THE 2003 EXAMINATION OF OUR FIRM. REVISED PROCEDURES WERE PREPARED AND GIVEN TO THE NASD EXAMINER WHO CONDUCTED THE REVIEW. THESE PROCEDURES INCLUDE, AMOUNG OTHER THINGS, REVIEWING TRANSACTIONS BY UTILIZING THE "TRADE REPORTING SYSTEM" FUNCTION OF THE TRACE WEB SITE.
 


Signature Page

DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments.

Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives.
Signature:
ANTHONY VERGA 		Date: MM/DD/YYYY
10/14/2014
Printed Name:
ANTHONY VERGA 		Title:
CCO/MANAGING DIRECTOR/HEAD OF PCS COMPLIANCE
Adviser CRD Number:
19585
 

NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners.
3. Non-Resident Investment Adviser Undertaking Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission, correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940. This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of attorney or any of your general partners and managing agents.
Signature

I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives.
Signature:
Date: MM/DD/YYYY
Printed Name:
 Title:
Adviser CRD Number:
19585